Uncangco v. Colvin

Filing 17

ORDER Granting Plaintiff's 16 Unopposed Motion to Extend Time to File Motion for Remand and/or Reversal. Motions due by 2/23/2015. Responses due by 2/23/2015. Replies due by 3/9/2015. Signed by Magistrate Judge Peggy A. Leen on 12/3/2014. (Copies have been distributed pursuant to the NEF - SLD)

1
2
3
4

Marc V. Kalagian
Attorney at Law: 4460
Law Offices of Rohlfing & Kalagian, LLP
211 East Ocean Boulevard, Suite 420
Long Beach, CA 90802
Tel.: [phone]
Fax: [phone]
E-mail [e-mail]

5
6

Attorneys for Plaintiff
BETTY UNCANGCO

7
8
UNITED STATES DISTRICT COURT

9

DISTRICT OF NEVADA

10
11
12
13
14

BETTY UNCANGCO,
Plaintiff,
vs.

15

CAROLYN W. COLVIN, Acting

16

Commissioner of Social Security,

17
18
19
20
21
22
23
24
25

Defendant

)
)
)
)
)
)
)
)
)
)
)
)

Case No.: 2:14-cv-00994-APG-CWH
UNOPPOSED MOTION TO AMEND
AND EXTEND BRIEFING
SCHEDULE

Plaintiff Betty Uncangco (“Plaintiff”) and defendant Carolyn Colvin,
Commissioner of Social Security (“Defendant”), through their undersigned counsel
of record, hereby stipulate, subject to the approval of the Court, to extend the time
for Plaintiff to file Plaintiff’s Motion for Reversal and/or Remand to January 23,
2015; and that Defendant shall have until February 23, 2015, to file her opposition,
if any is forthcoming. Any reply by plaintiff will be due March 9, 2015.

26
27
28

-1-

1

An extension of time is needed because Plaintiff’s Counsel’s Spouse

2

undergoes chemotherapy treatment for her Stage IV breast cancer which

3

metastasized initially to her liver and continues to progress there and in her lungs,

4

throat, and spine which required recent hospitalization to treat. Counsel requires the

5

additional time to file the Motion for Reversal and/or Remand to allow him to

6

devote the appropriate time to assist his Spouse and his two elementary school aged

7

children through this obviously stressful experience. Counsel sincerely apologizes

8

to the court for any inconvenience this may have had upon it or its staff.

9

Counsel for defendant has indicated, via e-mail, that this motion to extend

10

the time to file is not opposed.

11

DATE: December 1, 2014,

12

Respectfully submitted,
ROHLFING & KALAGIAN, LLP

13

/s/ Marc V. Kalagian
BY: _________________________
Marc V. Kalagian
Attorney for plaintiff BETTY UNCANGCO

14
15
16
17

ORDER
18
IT IS SO ORDERED.
19
20
21

____________________________________
UNITED STATES MAGISTRATE JUDGE

22

DATED: December 3, 2014

23
24
25
26
27
28

-2-