Williams v. Commissioner of Social Security

Filing 15

ORDER Granting 14 Motion to Extend Time to File Defendant's Cross-Motion to Affirm. Motions due by 11/2/2016. Signed by Magistrate Judge George Foley, Jr on 10/3/16. (Copies have been distributed pursuant to the NEF - MMM)

GERALD M. WELT, SBN 1575
1 Attorney at Law
CYRUS SAFA
2 Attorney at Law, SBN 13241
12631 East Imperial Highway, Suite C-115
3
Santa Fe Springs, California 90670
Phone: [phone]
4
Fax: [phone]
[e-mail]
5
6 Attorneys for Plaintiff
7 DANIEL G. BOGDEN, NSBN 2137
United States Attorney
8 BLAINE T. WELSH
Chief, Civil Division
9 APRIL A. ALONGI, VSBN 76459
Special Assistant United States Attorney
10
160 Spear Street, Suite 800
San Francisco, California 94105
11
Phone: [phone]
Fax: [phone]
12
[e-mail]
13

Attorneys for Defendant

14

UNITED STATES DISTRICT COURT

15
DISTRICT OF NEVADA
16
ROBYN J. WILLIAMS,
17
18

Plaintiff
v.

19
CAROLYN W. COLVIN, Acting
20 Commissioner of Social Security,
21

Defendant.

)
)
)
)
)
)
)
)
)
)
)

Case No: 2:16-cv-00701-GMN-GWF
JOINT STIPULATION FOR EXTENSION
OF TIME TO FILE DEFENDANT’S
CROSS-MOTION TO AFFIRM
(First Request)

22
23
24
25
26

27
28

-1-

1

Plaintiff Robyn J. Williams (Plaintiff) and Defendant Carolyn W. Colvin, Acting

2 Commissioner of Social Security (the Commissioner), stipulate, with the approval of this Court,
3 to an extension of time for the Commissioner to file her Cross-Motion To Affirm by thirty days
4 from October 3, 2016 to November 2, 2016. This is the Commissioner’s first request for an
5 extension.
6

///

7

///

8

///

9

///

10

///

11

///

12

///

13

///

14

///

15

///

16

///

17

///

18

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

19 (Plaintiff’s Motion), counsel has been handling a large number of District Court and Ninth Circuit
20 cases in addition to this one, with seven briefs due within the next twenty-four days. Additionally,
21 the Commissioner’s counsel has had numerous other deadlines, including a District Court brief
22 filed September 30, 2016, five other District Court briefs filed, as well as several end-of-fiscal year
23 training courses, a number of conferences in an employment case, a settlement agreement, and
24 multiple mentoring and reviewing duties in the Office of the General Counsel. Counsel was also
25 out of the office for approximately two days. As result, the Commissioner needs additional time
26

27
28

-2-

1 to respond properly to the issues Plaintiff raised in her Motion. Plaintiff has no objection.
2
3

Respectfully submitted,

4 Date: September 30, 2016

GERALD M. WELT
Attorney at Law

5
By:

7

/s/* Cyrus Safa
CYRUS SAFA
*by email authorization on 9/30/16

8

Attorneys for Plaintiff

6

9

Date: September 30, 2016

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

10
11
12

By:

13

/s/ April A. Alongi
APRIL A. ALONGI
Special Assistant United States Attorney

14

Attorneys for Defendant

15
16
17
18
19

IT IS SO ORDERED.

20
21
22
23
24

DATE:

October 3, 2016
THE HONORABLE GEORGE FOLEY, JR.
United States Magistrate Judge

25
26

27
28

-3-

Case 2:16-cv-00701-GMN-GWF Document 14 Filed 09/30/16 Page 4 of 4

1

DEFENDANT'S CERTIFICATE OF SERVICE

2
3
4 I certify that I caused the Joint Stipulation For Extension Of Time To File Defendant’s Cross5 Motion To Affirm (First Request) to be served, via CM/ECF notice, on:
6
7
8
9

CYRUS SAFA
Attorney at Law
[e-mail]

10
Respectfully submitted,
11
12

Date: September 30, 2016

DANIEL G. BOGDEN
United States Attorney
DANIEL G. BOGDEN
Chief, Civil Division

13
14
15

By:

/s/ April A. Alongi
APRIL A. ALONGI
Special Assistant United States Attorney

16
Attorneys for Defendant
17
18
19
20
21
22
23
24
25
26

27
28

-4-