Chappell v. Commissioner of Social Security

Filing 17

ORDER Granting 16 Motion for Extension of Time. See Order for deadlines. Signed by Magistrate Judge Cam Ferenbach on 1/10/17. (Copies have been distributed pursuant to the NEF - ADR)

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1 2 3 4 5 6 DANIEL G. BOGDEN United States Attorney District of Nevada C. HAY-MIE CHO Special Assistant United States Attorney 160 Spear Street, Suite 800 San Francisco, CA 94596 Telephone No.: (415) 268-5610 Facsimile No.: (415) 744-0134 Email Address: haymie.cho@ssa.gov 7 Attorneys for Defendant 8 9 10 11 UNITED STATES DISTRICT COURT 12 DISTRICT OF NEVADA 13 14 15 16 DAVE E. CHAPPELL Plaintiff, v. CAROLYN W. COLVIN, Acting Commissioner of Social Security, 17 18 Defendant. ) ) Case No. 2:16-cv-01940-APG-VCF ) ) ) UNOPPOSED MOTION FOR ) EXTENSION OF TIME ) (FIRST REQUEST) ) ) ) ) 19 20 Defendant Carolyn W. Colvin, Acting Commissioner of Social Security (“Defendant”) 21 respectfully requests that the Court extend the time for Defendant to file her Cross-Motion to Affirm, due 22 on December 19, 2016 by 30 days, through and including January 18, 2016. 23 An extension of time is needed in order to prepare Defendant’s Cross-Motion to Affirm because 24 the undersigned attorney has only recently been cleared as a Special Assistant United States Attorney, and 25 supervisory attorneys must review the Commissioner’s brief prior to filing. The undersigned currently 26 has 25 pending District Court and Circuit Court cases that are in various stages of litigation, handles -1- 1 employment and privacy matters for the agency, and is scheduled to be on vacation from December 19, 2 2016 through December 27, 2016. Counsel assigned to review the Commissioner’s brief currently has 45 3 District and Circuit Court cases that are in various stages of litigation, three of which require imminent 4 briefing, and additionally handles bankruptcy and other litigation matters for the agency. This request is 5 made in good faith with no intention to unduly delay the proceedings. 6 7 8 Counsel for Defendant conferred with Plaintiff’s counsel, who has no opposition to this motion, on December 7, 2016. Respectfully submitted this 9th day of December, 2016. 9 DANIEL G. BOGDEN United States Attorney 10 /s/ C. Hay-Mie Cho C. HAY-MIE CHO Special Assistant United States Attorney 11 12 13 14 15 OF COUNSEL: DEBORAH LEE STACHEL Regional Chief Counsel, Region IX 16 17 18 IT IS SO ORDERED: 19 20 21 UNITED STATES MAGISTRATE JUDGE 1-10-2017 DATED: 22 23 24 25 26 -2- 1 2 3 4 CERTIFICATE OF SERVICE I, C. Hay-Mie Cho, certify that the following individuals were served with a copy of the UNOPPOSED MOTION FOR EXTENSION OF TIME on the date and via the method of service identified below: CM/ECF: 5 6 7 8 9 10 11 12 Cyrus Safa Law Offices of Lawrence D. Rohlfing 12631 East Imperial Highway, Suite C-115 Santa Fe Springs, CA 90670 Cyrus.Safa@rohlfinglaw.com Leonard Stone Shooke & Stone, Chtd. 710 South 4th Street Las Vegas, NV 89101 LMoreno@shookandstone.com Dated this 9th day of December, 2016. 13 14 15 /s/ C. Hay-Mie Cho C. HAY-MIE CHO Special Assistant United States Attorney 16 17 18 19 20 21 22 23 24 25 26 -3-

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