Swartz v. Colvin

Filing 22

ORDER granting ECF No. 21 Motion to Extend Time : Cross-Motion to Affirm due by 6/27/2016; with all other dates in this Court's ECF No. 14 Scheduling Order extended accordingly. Signed by Magistrate Judge Peggy A. Leen on 5/31/2016. (Copies have been distributed pursuant to the NEF - DRM)

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RICHARD E. DONALDSON, NSBN 1095
Esquire
2300 West Sahara Avenue
Suite 800
Las Vegas, Nevada 89102
[e-mail]
Attorney for Plaintiff
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]
Attorneys for Defendant
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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FRANCES E. SWARTZ,

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

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Case No: 2:15-cv-01811-JAD-PAL
JOINT STIPULATION FOR EXTENSION
OF TIME TO FILE DEFENDANT’S
CROSS-MOTION TO AFFIRM

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Plaintiff Frances E. Swartz (Plaintiff) and Defendant Carolyn W. Colvin, Acting

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Commissioner of Social Security (the Commissioner), stipulate, with the approval of this Court,

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to an extension of time to file Defendant’s Cross-Motion To Affirm by thirty-two days from May

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26, 2016 to June 27, 2016, with all other dates in this Court’s Scheduling Order extended

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accordingly. This is the Commissioner’s first request for an extension.1

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There is good cause because, since Plaintiff filed her Motion For Reversal And Remand,

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the Commissioner’s counsel has been handling a large number of District Court and Ninth

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Circuit cases in addition to this one, with eleven briefs—one in the Ninth Circuit—due within the

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next thirty days. Additionally, counsel has been had numerous other deadlines, including a

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motion to compel in a discovery dispute, a settlement memorandum in an employment case, and

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multiple mentoring and reviewing duties in the Office of the General Counsel. As result, the

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This Court granted the Commissioner an extension of time prior to answering Plaintiff’s
Complaint For Judicial Review because the Social Security Administration component
responsible for producing the certified administrative record had not yet provided it to counsel.
That extension occurred prior to briefing.

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Commissioner needs additional time to properly respond to the issues Plaintiff raised in her

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motion. Plaintiff has no objection.

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Respectfully submitted,
Date: May 26, 2016
By:

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/s/* Richard E. Donaldson
RICHARD E. DONALDSON
*by email authorization on 5/26/16

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Attorney for Plaintiff

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Date: May 26, 2016

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:

May 31, 2016
THE HONORABLE PEGGY A. LEEN
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 Joint Stipulation For Extension Of Time To File Defendant’s

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

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RICHARD E. DONALDSON
Esquire
[e-mail]

Date: May 26, 2016

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

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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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By:

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