Ruditsky v. Saul

Filing 21

ORDER Granting 19 Motion to Extend Time re 17 Motion to Remand to Agency (First Request). Responses due by 4/8/2021. Signed by Magistrate Judge Daniel J. Albregts on 3/24/2021. (Copies have been distributed pursuant to the NEF - MR)

Case 2:20-cv-01285-DJA Document 21 Filed 03/24/21 Page 1 of 3

1 CHRISTOPHER CHIOU, NVSBN 14853
Acting United States Attorney
2 District of Nevada
3 Chantal Jenkins
Special Assistant United States Attorney
4 Social Security Administration
160 Spear Street, Suite 800
5 San Francisco, CA 94105
Telephone: [phone]
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Email: [e-mail]
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Attorneys for Defendant
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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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SUSAN NEELY RUDITSKY,

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Plaintiff,

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v.

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ANDREW SAUL,
Commissioner of Social Security,
Defendant.

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Case No.: 2:20-cv-01285-DJA
UNOPPOSED MOTION FOR
EXTENSION OF TIME TO RESPOND TO
PLAINTIFF’S MOTOIN FOR REVERAL
AND/OR REMAND (FIRST REQUEST)

Defendant Andrew Saul, Commissioner of Social Security (“Defendant”) respectfully requests

21 that the Court extend the time for Defendant to respond to Plaintiff’s Motion for Reversal and/or
22 Remand (Motion) from March 25, 2021 to April 8, 2021. This is Defendant’s first request for
23 extension to respond to Plaintiff’s Motion and third request in this case. Defendant respectfully
24 requests this additional time because counsel was recently reassigned this case and has been out of the
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office on leave. Counsel currently has three briefs due in other social security cases within the next

Case 2:20-cv-01285-DJA Document 21 Filed 03/24/21 Page 2 of 3

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month and additionally has to train a new attorney hire. Counsel, therefore, requests an additional
fourteen days to file Defendant’s response. Counsel contacted Plaintiff on March 23, 2021 and

3 Plaintiff does not object to this request.
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This request is made in good faith with no intention to unduly delay the proceedings.

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Counsel apologizes to the Court for any inconvenience caused by this delay.

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Respectfully submitted this 23rd day of March 2021.

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CHRISTOPHER CHIOU
Acting United States Attorney

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/s/ Chantal R. Jenkins
CHANTAL R. JENKINS
Special Assistant United States Attorney

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OF COUNSEL:

DEBORAL LEE STACHEL
16 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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March 24, 2021
DATED:____________________________

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Case 2:20-cv-01285-DJA Document 19 Filed 03/23/21 Page 3 of 3
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03/24/21

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CERTIFICATE OF SERVICE

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I, Chantal R. Jenkins, certify that the following individual was served with a copy of the

4 MOTION FOR EXTENSION OF TIME on the date and via the method of service identified below:
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Gerald Morris Welt
Gerald M. Welt, Chtd.
411 E. Bonneville Ave., #505
Las Vegas, NV 89101
702-382-2030
Fax: [phone]
Email: [e-mail]
ATTORNEY TO BE NOTICED

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Marc V Kalagian
Rohlfing & Kalagian, LLP
211 E. Ocean Blvd.
Suite 420
Long Beach, CA 90802
[phone]
Fax: [phone]
Email: [e-mail]
ATTORNEY TO BE NOTICED

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I declare under penalty of perjury that the foregoing is true and correct.
Dated: March 23, 2021

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/s/ Chantal R. Jenkins
CHANTAL R. JENKINS
Special Assistant United States Attorney

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