Gill v. Colvin

Filing 24

ORDER Granting 22 Stipulation for Extension (Third Request). Signed by Magistrate Judge Carl W. Hoffman on 12/16/15. (Copies have been distributed pursuant to the NEF - PS)

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DANIEL G. BOGDEN
United States Attorney
District of Nevada
DANIEL P. TALBERT
Special Assistant United States Attorney
Social Security Administration
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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TAMMY A. GILL,
Plaintiff,

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No. 2:15-cv-00553-JCM-CWH

v.

STIPULATION AND PROPOSED ORDER FOR
EXTENSION

CAROLYN W. COLVIN,
Acting Commissioner of Social Security,

(THIRD REQUEST)

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Defendant.

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The parties request to extend the time by three days from December 14, 2015, to

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December 17, 2015, for Defendant Carolyn W. Colvin, Acting Commissioner of Social Security

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(the Commissioner), to file her Cross-Motion to Affirm. This is the Commissioner’s third request

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for an extension.

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There is good cause for this extension. The Commissioner has previously requested and

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received two extensions of time to file her responsive brief in this matter. Since the filing of

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Plaintiff’s motion, scheduling and workload commitments led to the assignment and reassignment

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of this case to three different attorneys for the Commissioner. The undersigned attorney for the

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Commissioner learned of this matter for the first time this morning, and agreed to accept

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reassignment of the case, resolve the scheduling issue, and prepare and submit the

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Commissioner’s Motion to Affirm as promptly as possible. The undersigned attorney for the

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Commissioner has made this matter his top priority and will attempt to file his Motion to Affirm

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either today, December 15, 2015, or tomorrow, December 16, 2015, but at the latest by Thursday,

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December 17, 2015. The undersigned attorney for the Commissioner apologizes to the Court and

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to opposing counsel for making this additional request for additional time, and for the failure to

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file the Motion to Affirm yesterday as required by this Court’s prior order. Counsel for Plaintiff

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does not oppose this request, and joins in this stipulation to grant the Commissioner a third

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extension of three days.

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Respectfully submitted,

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DANIEL G. BOGDEN
United States Attorney

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DATE: December 15, 2015

By

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s/ Daniel P. Talbert
DANIEL P. TALBERT
Special Assistant United States Attorney
Attorneys for Defendant

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By

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s/ Marc V. Kalagian
MARC V. KALAGIAN
*by email authorization December 15, 2015
Attorney for Plaintiff

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IT IS SO ORDERED.

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DATE: _________________
December 16, 2015

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THE HONORABLE C. W. HOFFMAN, JR.
United States Magistrate Judge

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