Barbour v. Colvin

Filing 13

ORDER on 12 Stipulation for Extension of Time to file Defendant's Cross-Motion to Affirm : Motion due by 2/22/2016. Signed by Magistrate Judge William G. Cobb on 1/22/2016. (Copies have been distributed pursuant to the NEF - DRM)

Case 3:15-cv-00380-HDM-WGC Document 12 Filed 01/22/16 Page 1 of 3

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MARC V. KALAGIAN
Attorney at Law
211 East Ocean Boulevard, Suite 420
Long Beach, California 90802
[e-mail]

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Attorney for Plaintiff

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DANIEL G. BOGDEN, NSBN 2137
United States Attorney
HOLLY A. VANCE
Assistant United States Attorney
APRIL A. ALONGI, VSBN 76459
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105
Phone: [phone]
Fax: [phone]
[e-mail]

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Attorneys for Defendant
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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DANYL W. BARBOUR,

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Plaintiff
v.

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CAROLYN W. COLVIN, Acting
Commissioner of Social Security,
Defendant.

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Case No: 3:15-cv-00380-HDM-WGC
JOINT STIPULATION FOR EXTENSION
OF TIME TO FILE DEFENDANT’S
CROSS-MOTION TO AFFIRM

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Plaintiff Danyl W. Barbour (Plaintiff) and Defendant Carolyn W. Colvin, Acting

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Commissioner of Social Security (the Commissioner), stipulate, with the approval of this Court,

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to an extension of time to file the Commissioner’s Cross-Motion To Affirm by thirty-one days

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from January 22, 2016 to February 22, 2016. This is the Commissioner’s first request for an

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extension.

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Case 3:15-cv-00380-HDM-WGC Document 12 Filed 01/22/16 Page 2 of 3

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There is good cause because Commissioner’s counsel was assigned a new employment

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case this week, which requires imminent attention. Further, counsel has three other briefs due

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this week, an upcoming 9th Circuit oral argument, and a brief in a different 9th Circuit case due

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to be filed in less than three weeks. The Commissioner needs additional time to respond to the

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issues Plaintiff raised in his Motion For Reversal And/Or Remand. Plaintiff has no objection.

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Respectfully submitted,

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Date: January 22, 2016
By:

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/s/* Marc V. Kalagian
MARC V. KALAGIAN
Attorney at Law
*by email authorization on 1/21/16

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Attorney for Plaintiff

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Date: January 22, 2016

DANIEL G. BOGDEN
United States Attorney
HOLLY A. VANCE
Assistant United States Attorney

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By:

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

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IT IS SO ORDERED.

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DATED: January 22, 2016.

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DATE:

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____________________________________
WILLIAM G. COBB
THE HONORABLE CAM FERENBACH
UNITED STATES MAGISTRATE JUDGE
United States Magistrate Judge

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