Dearman v. Colvin

Filing 16

ORDER Granting 15 Stipulation. Carolyn W. Colvin answer due 3/13/2016. Signed by Magistrate Judge Peggy A. Leen on 2/22/16. (Copies have been distributed pursuant to the NEF - TR)

Case 2:15-cv-01447-GMN-PAL Document 15 Filed 02/12/16 Page 1 of 3

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DANIEL G. BOGDEN
United States Attorney
District of Nevada

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CAROLYN B. CHEN, C.S.B.N. 256628
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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Attorneys for Defendant

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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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MICHAEL DEARMAN,
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Plaintiff,
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v.
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CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

)
) Case No. 2:15-cv-01447-GMN-PAL
)
)
) STIPULATION AND PROPOSED ORDER
)
FOR EXTENSION OF TIME FOR
)
DEFENDANT TO FILE ANSWER AND
)
SERVE COPY OF THE CERTIFIED
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ADMINISTRATIVE RECORD
)
)

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IT IS HEREBY STIPULATED, by and between the parties, through their respective counsel of
record, that Defendant shall have a first extension of time of 30 days to file her answer and a serve a
complete copy of the certified administrative record of the administrative proceedings, to be continued
from February 12, 2016, to March 13, 2016.
This is the first continuance sought by Defendant. Defendant’s counsel requests the continuance

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due to the fact that the Social Security Administration’s records component receives an extensive

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volume of requests for records nationally, and Defendant requires the additional time requested to

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properly compile and produce the certified administrative record to be utilized by all parties in this suit.

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Case 2:15-cv-01447-GMN-PAL Document 15 Filed 02/12/16 Page 2 of 3

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Therefore, with this Court’s approval, the Court’s scheduling order shall be extended by 30 days,

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so that Defendant may serve a copy of the certified administrative record and file her answer on or

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before March 13, 2016.

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Respectfully submitted,
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Dated: February 12, 2016

Law Offices of Rohlfing & Kalagian, LLP

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/s/ Marc Kalagian
(as authorized via e-mail on 2/11/2016)
Marc Kalagian
Attorneys for Plaintiff

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Dated: February 12, 2016

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DANIEL G. BOGDEN
United States Attorney
/s/ Carolyn B. Chen
CAROLYN B. CHEN
Special Assistant United States Attorney

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ORDER
PURSUANT TO THE STIPULATION, IT IS SO ORDERED.
February 22, 2016
DATED:________________________

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HON. PEGGY A. LEEN
UNITED STATE MAGISTRATE JUDGE

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Case 2:15-cv-01447-GMN-PAL Document 15 Filed 02/12/16 Page 3 of 3

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CERTIFICATE OF SERVICE
I, Carolyn B. Chen, certify that the following individual was served with a copy of the
STIPULATION AND PROPOSED ORDER FOR EXTENSION OF TIME FOR DEFENDANT
TO FILE ANSWER AND SERVE COPY OF THE CERTIFIED ADMINISTRATIVE RECORD
on the date and via the method of service identified below:

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CM/ECF:
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Marc V. Kalagian
Law Offices of Rohlfing & Kalagian, LLP
211 East Ocean Boulevard, Suite 420
Long Beach, CA 90802
[e-mail]

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Dated this 12th day of February 2016.

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/s/ Carolyn B. Chen
CAROLYN B. CHEN
Special Assistant United States Attorney

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