Pinkston v. Saul

Filing 32

ORDER granting 31 Motion to Extend Time Re: 30 Motion to Remand to Agency. Responses due by 7/9/2021. Signed by Magistrate Judge Elayna J. Youchah on 6/3/2021. (Copies have been distributed pursuant to the NEF - HAM)

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CHRISTOPHER CHIOU
Acting United States Attorney
District of Nevada
Nevada Bar No. 14853

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ALLISON J. CHEUNG, CSBN 244651
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [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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F.G. PINKSTON,
Plaintiff,

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vs.
ANDREW SAUL,
Commissioner of Social Security,
Defendant.

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Case No.: 2:20-cv-01747-EJY
MOTION FOR EXTENSION OF TIME;
[PROPOSED] ORDER
(FIRST REQUEST)

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

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the Court extend the time for Defendant to respond to Plaintiff’s Motion for Reversal and/or Remand

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(Dkt. No. 30, filed on May 12, 2021 but served on May 10, 2021), currently due on June 9, 2021, by 30

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days, through and including July 9, 2021. Defendant further requests that all subsequent deadlines set

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forth in the Court’s scheduling order (Dkt. No. 26) be extended accordingly.

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This is Defendant’s first request for an extension of time. Good cause exists for this extension

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because Defendant’s counsel is in the process of conferring with her client to determine whether this

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matter can be resolved by settlement. The additional requested time will also allow for potential

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settlement discussions with Plaintiff, and if the matter cannot be resolved, to allow counsel to prepare a

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response to Plaintiff’s pending motion. Defendant’s counsel will endeavor to complete these tasks as

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soon as possible. However, counsel currently has seven cases in the active briefing stage that also require

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her attention. This request is made in good faith and with no intention to unduly delay the proceedings,

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and counsel apologizes for any inconvenience.

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On June 2, 2021, counsel for Defendant conferred with Plaintiff, who opposes this motion.

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It is therefore respectfully requested that Defendant be granted an extension of time to respond to

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Plaintiff’s Motion for Reversal and Remand, through and including July 9, 2021.

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Dated: June 2, 2021
CHRISTOPHER CHIOU
Acting United States Attorney

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/s/ Allison J. Cheung
ALLISON J. CHEUNG
Special Assistant United States Attorney

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IT IS SO ORDERED.

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___________________________________
U.S. MAGISTRATE JUDGE

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Dated: June 3, 2021
Mot. for Ext.; No 2:20-cv-01747-EJY