Opinion
CASE NO.: 2:11-CV-0394 JCM-CWH
08-31-2011
PATRICIA J. SHANNON Plaintiff, v. MICHAEL J. ASTRUE, COMMISSIONER OF SOCIAL SECURITY, Defendant.
RICHARD E. DONALDSON, ESQ. Nevada Bar No. 1095 Las Vegas, NV 89102 Attorney for Plaintiff
RICHARD E. DONALDSON, ESQ., CHTD.
RICHARD E. DONALDSON, ESQ.
Nevada Bar No. 1095
Las Vegas, NV 89102
Attorney for Patricia Shannon
PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION OF
TIME TO FILE A MOTION FOR REVERSAL AND/OR REMAND
(First Request)
Plaintiff, PATRICIA J. SHANNON by and through her attorney of record, RICHARD E. DONALDSON, ESQ., respectfully requests an extension of time of an additional thirty (30) days, to and including, Friday, September 30, 2011, in which to file a Motion for Reversal and/or Remand.
This request is necessary so that the Plaintiff can complete additional research, and finish the writing, which has taken much longer than anticipated. At the present time, Plaintiff's deadline to file the Motion for Reversal and/or Remand is Friday, August 5, 2011, and counsel has been unable to finish the brief by today.
This request is being filed as a Motion as the undersigned counsel contacted Carlos A. Gonzalez, Assistant United States Attorney and counsel of record for the Defendant, and Mr. Gonzalez does not oppose this Motion.
This is the first request for an extension of time to file the Motion.
Respectfully submitted,
RICHARD E. DONALDSON, ESQ., CHTD.
RICHARD E. DONALDSON, ESQ.
Nevada Bar No. 1095
Las Vegas, NV 89102
Attorney for Plaintiff
IT IS SO ORDERED:
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UNITED STAGES MAGISTRATE JUDGE