Castle v. Colvin

Filing 12

ORDER granting 11 Motion to Extend Time. Carolyn W. Colvin answer due 2/2/2017. Signed by Magistrate Judge George Foley, Jr on 1/4/2017. (Copies have been distributed pursuant to the NEF - JM)

Case 2:16-cv-02412-GMN-GWF Document 11 Filed 01/03/17 Page 1 of 3

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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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JASON S. CASTLE,
Plaintiff,
v.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,

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Defendant.

)
) Case No. 2:16-cv-02412-GMN-GWF
)
)
)
UNOPPOSED MOTION FOR
)
EXTENSION OF TIME
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(FIRST REQUEST)
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)

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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 Answer, due on January 3,

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2017 by 30 days, through and including February 2, 2017.

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Defendant needs additional time to draft and file her answer because the United States Attorney’s

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Office has not yet received the Certified Administrative Record (CAR). Therefore, Defendant is unable

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to file the CAR with her Answer. Defendant contacted Plaintiff’s counsel, Marc A. Kalagian, by telephone

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on January 3, 2017, but was unable to reach Plaintiff’s counsel, Gerald Welt. Mr. Kalagian informed

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Case 2:16-cv-02412-GMN-GWF Document 11 Filed 01/03/17 Page 2 of 3

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Defendant that he would authorize Defendant’s request on Mr. Welt’s behalf. This request is made in

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good faith with no intention to unduly delay the proceedings.

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Respectfully submitted this 3rd day of January, 2017.

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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

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DATED: January 4, 2017

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Case 2:16-cv-02412-GMN-GWF Document 11 Filed 01/03/17 Page 3 of 3

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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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Marc V. Kalagian
Law Offices of Rohlfing & Kalagian, LLP
211 East Ocean Boulevard, Suite 420
Long Beach, CA 90802
[e-mail]
Gerald M. Welt
732 S. Sixth Street, Suite 200-D
Las Vegas, NV 89101
[e-mail]; [e-mail]
Dated this 3rd day of January, 2017.
/s/ C. Hay-Mie Cho
C. HAY-MIE CHO
Special Assistant United States Attorney

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