Swartz v. Colvin

Filing 17

ORDER Granting 16 Motion to Extend Time. Motion due by 4/25/2016. Signed by Magistrate Judge Peggy A. Leen on 3/25/16. (Copies have been distributed pursuant to the NEF - TR)

Case 2:15-cv-01811-JAD-PAL Document 16 Filed 03/22/16 Page 1 of 2

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RICHARD E. DONALDSON, ESQ., CHTD.
RICHARD E. DONALDSON, ESQ.
Nevada Bar No. 1095
2300 West Sahara Ave., Suite 800
Las Vegas, NV 89102
Attorney for Plaintiff

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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******

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FRANCES E. SWARTZ

)
)
)
Plaintiff,
)
)
vs.
)
) CIVIL ACTION NO. 2:15-cv-01811-JAD-PAL
)
CAROLYN COLVIN
)
COMMISSIONER OF SOCIAL )
SOCIAL SECURITY
)
)
Defendant. )
______________________________)

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MOTION FOR AN EXTENSION OF TIME TO FILE A

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MOTION FOR REVERSAL/REMAND

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(First Request)

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FRANCES E. SWARTZ by and through her counsel of record, Richard E. Donaldson,

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Esq. respectfully moves for a thirty-one (31) day extension of time to and including

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Monday, April 25, 2016 in which to file a Motion for Reversal/Remand. The briefing

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schedule [Doc. #14] currently requires that this motion be filed by March 23, 2016.

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Counsel became aware of a new Social Security Ruling (SSR 16-3) that may [or may not]

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bear on the outcome of this litigation, and requires additional time to consider what effects

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the new Ruling would have on any future proceedings, should there be any.

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This request is being filed as a Motion as undersigned Counsel attempted to

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contact April Alongi, Esq., of the Office of General Counsel, and counsel of record for the

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Defendant, but she is unavailable at this time. However, attorneys at the Office of General

Case 2:15-cv-01811-JAD-PAL Document 16 Filed 03/22/16 Page 2 of 2

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Counsel have not opposed undersigned Counsel’s Motion(s) for Extension of Time in forty-

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three years, he cannot think of any reason the OGC would start now, requests to allow

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extensions of time have always been routinely accepted as a matter of courtesy, the

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Defendant would not be prejudiced in any way, and on that basis believes that Ms. Alongi

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or the Office of General Counsel would have no objection to this Motion.

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The Federal Rules of Civil Procedure provide for an enlargement of time for cause
shown.

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When an act may or must be done within a specified time, the court may, for good

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cause, extend the time . . . if a request is made, before the original time or its

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extension expires . . . .

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Fed. R. Civ. P., Rule 6(b).

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This request is made prior to the expiration of time permitted to file a Motion to

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Reversal/Remand.

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DATED this 22nd day of March, 2016.

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Respectfully submitted,

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RICHARD E. DONALDSON, ESQ., CHTD.

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Richard E. Donaldson ________
Nevada Bar No. 1095
2300 West Sahara Ave., Suite 800
Las Vegas, NV 89102
Attorney for Plaintiff

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IT IS SO ORDERED:

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UNITED STATES MAGISTRATE JUDGE

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__________________________________________

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March 25, 2016
Date: --------------------------------------------------------

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