Garcia v. Carolyn W. Colvin
Filing
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ORDER Granting 19 Motion to Extend Time re 18 Motion to Remand to Agency. ( Responses due by 11/23/2016.) Signed by Magistrate Judge Nancy J. Koppe on 10/24/16. (Copies have been distributed pursuant to the NEF - ADR)
Case 2:16-cv-01018-APG-NJK Document 19 Filed 10/21/16 Page 1 of 3
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DANIEL G. BOGDEN
United States Attorney
District of Nevada
TIMOTHY R. BOLIN, CSBN 259511
Special Assistant United States Attorney
Social Security Administration
Office of the General Counsel
160 Spear St Ste 800
San Francisco, CA 94105
Telephone: (415) 977-8982
Facsimile: (415) 744-0134
Email: timothy.bolin@ssa.gov
Attorneys for Defendant
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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MARCOS GARCIA,
Plaintiff,
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v.
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CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
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Defendant.
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) Case No. 2:16-cv-01018-APG-NJK
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UNOPPOSED MOTION FOR
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EXTENSION OF TIME
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(FIRST REQUEST)
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Defendant Carolyn W. Colvin, Acting Commissioner of Social Security (“Defendant”),
respectfully requests that the time for Defendant to file her response to Plaintiff’s Motion for Summary
Judgment be extended from October 24, 2016 to November 23, 2016. This is Defendant’s first request
for an extension of time to respond to Plaintiff’s Motion for Summary Judgment.
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Case 2:16-cv-01018-APG-NJK Document 19 Filed 10/21/16 Page 2 of 3
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Defendant requests this extension due to her attorney’s inordinately heavy caseload in October
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2016 through November 2016, including 4 other briefs and 1 post-judgment motion due between
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October 24, 2016 and October 31, 2016 in the United States District Court for the Northern District of
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California, Eastern District of California, Central District of California and District of Nevada.
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Defendant’s counsel respectfully requests this additional time to review the Administrative Record, and
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to evaluate and respond to Plaintiff’s arguments.
This request is made in good faith with no intention to unduly delay the proceedings.
Counsel for Defendant conferred with Plaintiff’s counsel, who has no opposition to this motion,
on October 21, 2016.
Respectfully submitted October 21, 2016.
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DANIEL G. BOGDEN
United States Attorney
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/s/ Timothy R. Bolin
TIMOTHY R. BOLIN
Special Assistant United States Attorney
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OF COUNSEL:
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DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
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BEATRICE NA
Assistant Regional Counsel
IT IS SO ORDERED:
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UNITED STATES MAGISTRATE JUDGE
October 24, 2016
DATED:
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