Real de Ragan v. Colvin

Filing 14

ORDER Granting 13 Motion to Extend Time to File Cross-Motion to Affirm. (Motion due by 6/5/17.) Signed by Magistrate Judge Peggy A. Leen on 5/5/17. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:16-cv-02468-JAD-PAL Document 13 Filed 05/05/17 Page 1 of 4

1 MARC V. KALAGIAN, SBN 4460
Attorney at Law
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211 East Ocean Boulevard, Sutie 420
Long Beach, California 90802
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Phone: [phone]
Fax: [phone]
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[e-mail]
5 Attorney for Plaintiff
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STEVEN W. MYHRE, NSBN 9635
Acting United States Attorney
BLAINE T. WELSH
Chief, Civil Division
APRIL A. ALONGI, VSBN 76459
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Phone: [phone]
Fax: [phone]
[e-mail]

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Attorneys for Defendant
UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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16 TANIA V. REAL DE RAGAN,
Plaintiff
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v.
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19 NANCY A. BERRYHILL, Acting
Commissioner of Social Security,1
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Defendant.

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Case No: 2:16-cv-02468-JAD-PAL
JOINT STIPULATION FOR EXTENSION
OF TIME TO FILE DEFENDANT’S
CROSS-MOTION TO AFFIRM
(First Request)

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Nancy A. Berryhill is now the Acting Commissioner of Social Security. Pursuant to Rule 25(d)
of the Federal Rules of Civil Procedure, Nancy A. Berryhill should be substituted for Carolyn W.
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Colvin as the defendant in this suit. No further action needs to be taken to continue this case by
26 reason of the last sentence of section 205(g) of the Social Security Act. 42 U.S.C. § 405(g).

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Case 2:16-cv-02468-JAD-PAL Document 13 Filed 05/05/17 Page 2 of 4

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Plaintiff Tania V. Real De Ragan (Plaintiff) and Defendant Nancy A. Berryhill, 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-one
4 days from May 5, 2017 to June 5, 2017, with all other dates in this Court’s Scheduling Order
5 extended accordingly. This is the Commissioner’s first request for an extension.
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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 cases in addition
20 to this one, with two briefs due this week, three briefs due next week, and a settlement conference
21 next week, as well. Additionally, the Commissioner’s counsel will be out of the office on approved
22 leave for four days next week. Further, counsel has had numerous other deadlines in the past
23 month, including other District Court briefs, a settlement memorandum, and ongoing discovery in
24 an employment case which was completed this week. As a result, the Commissioner needs
25 additional time to properly respond to the issues Plaintiff raised in her Motion. Plaintiff has no
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Case 2:16-cv-02468-JAD-PAL Document 13 Filed 05/05/17 Page 3 of 4

1 objection.
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Respectfully submitted,

3 Date: May 5, 2017
By:

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/s/* Marc V. Kalagian
MARC V. KALAGIAN
Attorney at Law
*by email authorization on 5/4/17
Attorney for Plaintiff

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Date: May 5, 2017

STEVEN W. MYHRE
Acting United States Attorney
BLAINE T. WELSH
Chief, Civil Division

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By:

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

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Attorneys for Defendant

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IT IS SO ORDERED.

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20 DATE:
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May 5, 2017
THE HONORABLE PEGGY A. LEEN
United States Magistrate Judge

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Case 2:16-cv-02468-JAD-PAL Document 13 Filed 05/05/17 Page 4 of 4

DEFENDANT'S CERTIFICATE OF SERVICE

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3 I certify that I caused the Joint Stipulation For Extension Of Time To File Defendant’s Cross4 Motion To Affirm (First Request) to be served, via CM/ECF notice, on:
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MARC V. KALAGIAN
Attorney at Law
[e-mail]

Date: May 5, 2017

STEVEN W. MYHRE
Acting United States Attorney
BLAINE T. WELSH
Chief, Civil Division

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

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Attorneys for Defendant

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By:

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