Vella v. Colvin

Filing 16

ORDER Granting 15 Unopposed Motion re 12 Motion to Remand to Agency. Responses due by 2/4/2016. Signed by Magistrate Judge George Foley, Jr on 1/21/16. (Copies have been distributed pursuant to the NEF - TR)

Case 2:15-cv-01560-APG-GWF Document 15 Filed 01/20/16 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
(Second 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 15 days from
January 20, 2015 to February 4, 2016. This is Defendant’s second request for an extension of time to
respond to Plaintiff’s Motion. Counsel for Defendant contacted Plaintiff’s counsel on January 19,
2016, and Plaintiff’s counsel responded on January 19, 2016 that he does not oppose Defendant’s
motion. Defendants’ current deadline is January 20, 2016.

Case 2:15-cv-01560-APG-GWF Document 15 Filed 01/20/16 Page 2 of 3

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The instant request is not intended to cause delay and is necessary because of the heavy

2 workload of counsel for Defendant, and to allow the parties additional time to pursue potential
3 settlement of this matter.
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It is therefore respectfully requested that Defendant be granted a fifteen (15) day extension of

5 time to respond to Plaintiff's motion, up to and including February 4, 2016.
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Dated: January 20, 2016.

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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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12 OF COUNSEL:
13 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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January 21, 2016
DATED: ___________________________

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Case 2:15-cv-01560-APG-GWF Document 15 Filed 01/20/16 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 20th day of January, 2016

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

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