Morales v. Colvin

Filing 15

ORDER Granting 14 Motion to Extend Time To File Cross-Motion To Affirm or Notice Of Voluntary Remand. Motions due by 9/7/2016. Signed by Magistrate Judge Nancy J. Koppe on 8/10/16. (Copies have been distributed pursuant to the NEF - DL)

Case 2:16-cv-00230-JAD-NJK Document 14 Filed 08/08/16 Page 1 of 3

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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]

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Attorneys for Defendant

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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TERESA MORALES,
Plaintiff

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

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Case No: 2:16-cv-00230-JAD-NJK
DEFENDANT’S MOTION FOR
EXTENSION OF TIME TO FILE CROSSMOTION TO AFFIRM OR NOTICE OF
VOLUNTARY REMAND OF THE CASE
(Second Request)

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Defendant Carolyn W. Colvin, Acting Commissioner of Social Security (the

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Commissioner), moves, with the approval of this Court, for an extension of time to file her

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Cross-Motion To Affirm or Notice Of Voluntary Remand Of The Case by thirty days from

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August 8, 2016 to September 7, 2016, with all other dates in this Court’s Order Concerning

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Review Of Social Security Cases extended accordingly. This is the Commissioner’s second

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request for an extension.

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There is good cause because, since the prior extension, counsel has been handling a large

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number of District Court and Ninth Circuit cases in addition to this one, with counsel has been

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handling a large number of District Court and Ninth Circuit cases in addition to this one, with

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twelve briefs—one in the Ninth Circuit—due within the next thirty days. Additionally, the

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Case 2:16-cv-00230-JAD-NJK Document 14 Filed 08/08/16 Page 2 of 3

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Commissioner’s counsel has had numerous other deadlines, including a dispositive motion in an

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employment case, a settlement memorandum, and multiple mentoring and reviewing duties in

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the Office of the General Counsel. Counsel had a conference in an employment matter and was

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also out of the office for five days. As result, the Commissioner needs additional time to

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properly respond to the issues Plaintiff raised in her Motion. Counsel makes this request in good

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faith without any intention to unnecessarily delay these proceedings.

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counsel contacted Plaintiff, but at the time of filing, had not yet heard back.

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The Commissioner’s

Respectfully submitted,

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Date: August 8, 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
Attorneys for Defendant

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IT IS SO ORDERED.
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DATE:

August 10, 2016
THE HONORABLE NANCY J. KOPPE
United States Magistrate Judge

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Case 2:16-cv-00230-JAD-NJK Document 14 Filed 08/08/16 Page 3 of 3

DEFENDANT'S CERTIFICATE OF SERVICE

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I certify that I caused a copy of Defendant’s Motion For Extension Of Time To File Cross-

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Motion To Affirm Or Notice Of Voluntary Remand Of The Case (Second Request) to be served,

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via CM/ECF notice, on:

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RICHARD E. DONALDSON
Esquire
[e-mail]

Date: August 8, 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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