Morales v. Colvin

Filing 18

ORDER Granting 17 Stipulation For Extension Of Time To File Plaintiff's Reply To 16 Defendant's Cross Motion To Affirm. Replies due by 10/27/2016. Signed by Magistrate Judge Nancy J. Koppe on 9/27/2016. (Copies have been distributed pursuant to the NEF - DL)

Case 2:16-cv-00230-JAD-NJK Document 17 Filed 09/26/16 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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TERESA MORALES

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Plaintiff,
vs.

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CAROLYN COLVIN
COMMISSIONER OF SOCIAL
SOCIAL SECURITY
Defendant.

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CIVIL ACTION NO. 2:16-cv-00230 JAD-NJK

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STIPULATION FOR EXTENSION OF TIME TO FILE PLAINTIFF’S REPLY
TO DEFENDANT’S CROSS MOTION TO AFFIRM
(First Request)

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IT IS HEREBY STIPULATED, by and between the parties through their respective

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counsel, that the Plaintiff, TERESA MORALES, shall have an additional thirty (30) days, to

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and including Thursday, October 27, 2016 in which to file a REPLY TO DEFENDANT’S

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CROSS MOTION TO AFFIRM pursuant to this Court's Order Concerning Review of

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Social Security Cases, and that the schedule for briefing by the Defendant, Commissioner of

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Social Security, and other corresponding deadlines be adjusted accordingly.

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The extension of time is necessary because Counsel, a solo practitioner and solely

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responsible for the preparation this Reply, has not been able to adequately brief this case in

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the allotted time. The administrative record is detailed, and involves complex issues

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requiring additional time to research. Counsel has also had an unprecedented number of

Case 2:16-cv-00230-JAD-NJK Document 17 Filed 09/26/16 Page 2 of 2

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critical deadlines in other matters, and undersigned Counsel has not been able to meet all of

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these deadlines in a timely manner.

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This is the first request for an extension of time.

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Respectfully submitted,

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Date: September 26, 2016

RICHARD E. DONALDSON, ESQ., CHTD.

/S/Richard E. Donaldson

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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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Date: September 26, 2016

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DANIEL G. BOGDEN
United States Attorney
BLAINE T. WELSH
Chief, Civil Division
By: /s/ April A. Alongi
APRIL A. ALONGI
Special Assistant United States Attorney
Attorneys for Defendant

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IT IS SO ORDERED.
Date: September 27, 2016
THE HONORABLE NANCY J. KOPPE
Magistrate Judge