Weesner v. Colvin

Filing 16

ORDER Granting 15 Stipulation re 14 MOTION to Remand to Social Security Administration .( Responses due by 2/6/2017.) Signed by Magistrate Judge Peggy A. Leen on 12/30/16. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:16-cv-02018-RFB-PAL Document 15 Filed 12/29/16 Page 1 of 4

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Howard D. Olinsky
OLINSKY LAW GROUP
300 S. State Street, Ste 420
Syracuse, NY 13202
Ph: 315-701-5780
Fax: [phone]
Email: [e-mail]
Hal Taylor
223 Marsh Avenue
Reno, NV 89509
775-825-2223
Fax: [phone]
Email: [e-mail]

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Attorneys for Plaintiff
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DANIEL G. BOGDEN
United States Attorney
District of Nevada
ROYA MASSOUMI, CSBN 242697
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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THERESA M. WEESNER,
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Plaintiff,
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v.
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CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

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Case No. 2:16-cv-02018-RFB-PAL
JOINT STIPULATION AND [PROPOSED]
ORDER FOR EXTENSION OF TIME TO FILE
DEFENDANT’S NOTICE OF VOLUNTARY
REMAND OF THE CASE OR CROSSMOTION TO AFFIRM
(First Extension Request)

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Case 2:16-cv-02018-RFB-PAL Document 15 Filed 12/29/16 Page 2 of 4

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Plaintiff Theresa M. Weesner (Plaintiff) and Defendant Carolyn W. Colvin, Acting

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

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extension of time to file Defendant’s Notice Of Voluntary Remand Of The Case or Cross-Motion To

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Affirm by thirty days from the current deadline of January 6, 2017 to February 6, 2017, with all other

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dates in this Court’s Order Concerning Review Of Social Security Cases extended accordingly. This
is Defendant’s first request for an extension.

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Good cause exists to grant Defendant’s request for extension. Defendant respectfully requests
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additional time to adequately review the record, assess and evaluate Plaintiff’s arguments. Good cause
also exists because counsel for Defendant (Counsel) was on scheduled leave for the holidays and is
also expected to be out of the office from December 30, 2016 to January 3, 2017. Counsel needs

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additional time due to workload issues and current scheduling conflicts to properly respond to the

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issues Plaintiff raised in her Motion.

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Case 2:16-cv-02018-RFB-PAL Document 15 Filed 12/29/16 Page 3 of 4

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Defendant makes this request in good faith with no intention to unduly delay the proceedings.

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Plaintiff has no objection and has stipulated to the requested relief.

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Respectfully submitted this 29th day of December 2016,

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Date:

December 29, 2016
By:

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Date:

December 29, 2016

/s/*Howard Olinsky
Howard D. Olinsky
*by email authorization on 12/27/16
Attorney for Plaintiff
DANIEL G. BOGDEN
United States Attorney
HOLLY A. VANCE
Assistant United States Attorney

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By:
/s/ Roya Massoumi
ROYA MASSOUMI
Special Assistant United States Attorney

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Of Counsel:
TINA L. NAICKER
Assistant Regional Counsel
Attorneys for Defendant

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[PROPOSED] ORDER

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For good cause appearing therein, IT IS HEREBY ORDERED that the Joint Stipulation for

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Extension of Time to file Defendant’s Notice Of Voluntary Remand Of The Case or Cross-Motion To

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Affirm is GRANTED. Defendant shall file its response to Plaintiff’s Motion on or before February 6,

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2017. All other deadlines shall be extended accordingly.

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IT IS SO ORDERED.

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December 30,
Dated: _____________ 2016

_____________________________________________
THE HONORABLE PEGGY A. LEEN
United States Magistrate Judge

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Case 2:16-cv-02018-RFB-PAL Document 15 Filed 12/29/16 Page 4 of 4

CERTIFICATE OF SERVICE

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I, ROYA MASSOUMI, certify that the following individual was served with a copy of the

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JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO FILE

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DEFENDANT’S NOTICE OF VOLUNTARY REMAND OF THE CASE OR CROSS-

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MOTION TO AFFIRM on the date and via the method of service identified below:

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CM/ECF:
Howard D. Olinsky
Olinsky Law Group
300 S. State Street
Ste 420
Syracuse, NY 13202
315-701-5780
Fax: [phone]
Email: [e-mail]

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Hal Taylor
223 Marsh Avenue
Reno, NV 89509
775-825-2223
Fax: [phone]
Email: [e-mail]

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Respectfully submitted this 29th day of December 2016,

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/s/ Roya Massoumi
ROYA MASSOUMI
Special Assistant United States Attorney

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OF COUNSEL:
TINA L. NAICKER
Assistant Regional Counsel, Region IX

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