Vella v. Colvin

Filing 14

ORDER Granting 13 Unopposed Motion for Extension of Time re 12 Motion to Remand to Agency. Responses due by 1/20/2016. Signed by Magistrate Judge George Foley, Jr on 12/22/15. (Copies have been distributed pursuant to the NEF - TR)

Case 2:15-cv-01560-APG-GWF Document 13 Filed 12/21/15 Page 1 of 3

1 DANIEL G. BOGDEN
United States Attorney
2 District of Nevada
Nevada Bar No. 2137
3 MARLA K. LETELLIER
Special Assistant United States Attorney
4 California Bar No. 234969
160 Spear Street, Suite 800
5 San Francisco, CA 94105
Tel: [phone]
6 Fax: [phone]
Email: [e-mail]
7 Attorneys for Defendant
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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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

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UNOPPOSED MOTION FOR EXTENSION OF TIME
(First Request by Defendant)
COMES NOW Defendant Carolyn W. Colvin, Acting Commissioner of Social Security
(Defendant), by and through her counsel, Daniel G. Bogden, United States Attorney, and Marla
Letellier, Special Assistant United States Attorney, to request that this Court extend the time to

respond to Plaintiff's Motion for Remand, which was filed on November 18, 2015, by 30 days from
2016
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December 21, 2015 to January 20, 2015. This is Defendant’s first request for an extension of time to
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respond to Plaintiff’s Motion. Counsel for Defendant contacted Plaintiff’s counsel on December 18,
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2015, and Plaintiff’s counsel responded on December 21, 2015 that he does not oppose Defendant’s
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motion. Defendants’ current deadline is December 21, 2015.
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Case 2:15-cv-01560-APG-GWF Document 13 Filed 12/21/15 Page 2 of 3

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The instant request is not intended to cause delay and is necessary because counsel for

2 Defendant has been out of the office sick for more than a week, and because of the heavy workload of
3 counsel for Defendant, who is responsible for briefing dispositive motions in seven federal district
4 court cases between December 16, 2015 and January 7, 2016, as well as other agency matters.
It is therefore respectfully requested that Defendant be granted a thirty (30) day extension of
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6 time to respond to Plaintiff's motion, up to and including January 20, 2015.
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Dated: December 21, 2015.

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Respectfully submitted

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DANIEL G. BOGDEN
United States Attorney

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/s/ Marla K. Letellier
MARLA K. LETELLIER
Special Assistant United States Attorney

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13 OF COUNSEL:
14 DEBORAH STACHEL
Acting Regional Chief Counsel
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IT IS SO ORDERED:

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UNITED STATES MAGISTRATE JUDGE

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December 22, 2015
DATED: ___________________________

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Case 2:15-cv-01560-APG-GWF Document 13 Filed 12/21/15 Page 3 of 3

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CERTIFICATE OF SERVICE

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I, Marla Letellier, certify that the following individual(s) were served with a copy of the

3 foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME on the date, and via the method
4 of service, identified below:
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CM/ECF:
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David M. Moore, Esq.
Edward M. Bernstein & Associates
500 S. Fourth St.
Las Vegas, NV 89101
Email: [e-mail]

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Dated this 21st day of December, 2015

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/s/ Marla K. Letellier
MARLA K. LETELLIER
Assistant United States Attorney

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