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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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.: [phone]
Facsimile No.: [phone]
Email Address: [e-mail]

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Attorneys for Defendant
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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DAVE E. CHAPPELL
Plaintiff,
v.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,

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Defendant.

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) Case No. 2:16-cv-01940-APG-VCF
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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”)

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respectfully requests that the Court extend the time for Defendant to file her Cross-Motion to Affirm, due

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on December 19, 2016 by 30 days, through and including January 18, 2016.

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An extension of time is needed in order to prepare Defendant’s Cross-Motion to Affirm because

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the undersigned attorney has only recently been cleared as a Special Assistant United States Attorney, and

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supervisory attorneys must review the Commissioner’s brief prior to filing. The undersigned currently

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has 25 pending District Court and Circuit Court cases that are in various stages of litigation, handles

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employment and privacy matters for the agency, and is scheduled to be on vacation from December 19,

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2016 through December 27, 2016. Counsel assigned to review the Commissioner’s brief currently has 45

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District and Circuit Court cases that are in various stages of litigation, three of which require imminent

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briefing, and additionally handles bankruptcy and other litigation matters for the agency. This request is

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made in good faith with no intention to unduly delay the proceedings.

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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.

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DANIEL G. BOGDEN
United States Attorney

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/s/ C. Hay-Mie Cho
C. HAY-MIE CHO
Special Assistant United States Attorney

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OF COUNSEL:
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX

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IT IS SO ORDERED:

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UNITED STATES MAGISTRATE JUDGE
1-10-2017
DATED:

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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:

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Cyrus Safa
Law Offices of Lawrence D. Rohlfing
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
[e-mail]
Leonard Stone
Shooke & Stone, Chtd.
710 South 4th Street
Las Vegas, NV 89101
[e-mail]
Dated this 9th day of December, 2016.

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/s/ C. Hay-Mie Cho
C. HAY-MIE CHO
Special Assistant United States Attorney

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