Miers v. Colvin

Filing 14

ORDER Granting Defendant's 13 Motion for Extension of Time to File Cross-Motion to Affirm. Motions due by 1/18/2016. Signed by Magistrate Judge Cam Ferenbach on 1/6/2016. (Copies have been distributed pursuant to the NEF - SLD)

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DANIEL G. BOGDEN, NSBN 2137
United States Attorney
BLAINE T. WELSH
Chief, Civil Division
APRIL A. ALONGI, VSBN 76459
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105
Phone: [phone]
Fax: [phone]
[e-mail]

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Attorneys for Defendant

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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BETTY L. MIERS,

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Plaintiff
v.
CAROLYN W. COLVIN, Acting
Commissioner of Social Security,
Defendant.

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Case No: 2:15-cv-01229-JAD-VCF
DEFENDANT’S MOTION FOR
EXTENSION OF TIME TO FILE CROSSMOTION TO AFFIRM

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Defendant Carolyn W. Colvin, Acting Commissioner of Social Security (the

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Commissioner), moves, with the approval of this Court, for an extension of time to file her

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Cross-Motion To Affirm by thirty-one days from December 18, 2015 to January 18, 2016. This

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is the Commissioner’s first request for an extension.

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There is good cause because the Commissioner’s counsel is currently experiencing a

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heavy workload and has been out of the office unexpectedly. The Commissioner makes this

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request in good faith and needs additional time to respond to the issues Plaintiff Betty L. Miers
(Plaintiff) raised in her Motion For Judgment On The Pleadings. Counsel emailed Plaintiff
regarding this extension, but, at the time of filing, had not yet received a response.

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Respectfully submitted,
Date: December 18, 2015

DANIEL G. BOGDEN
United States Attorney
BLAINE T. WELSH
Chief, Civil Division

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By:

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/s/ April A. Alongi
APRIL A. ALONGI
Special Assistant United States Attorney

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Attorneys for Defendant

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IT IS SO ORDERED.

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DATE:

January 6, 2016
THE HONORABLE CAM FERENBACH
United States Magistrate Judge

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DEFENDANT'S CERTIFICATE OF SERVICE

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I certify that I caused a copy of the Defendant’s Motion For Extension Of Time To File Cross-

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Motion To Affirm to be served, via CM/ECF notification, on:

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DANIEL S. JONES
60 East 42nd Street, Suite 520
New York, New York 10165
[e-mail]
HAL TAYLOR
223 Marsh Avenue
Reno, Nevada 89505
[e-mail]
Date: December 18, 2015

DANIEL G. BOGDEN
United States Attorney
BLAINE T. WELSH
Chief, Civil Division

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By:
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/s/ April A. Alongi
APRIL A. ALONGI
Special Assistant United States Attorney
Attorneys for Defendant

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