Weesner v. Colvin

Filing 21

ORDER Granting 20 Stipulation for Extension of Time re 14 MOTION to Remand to Social Security Administration . Defendant shall file its response to Plaintiffs Motion on or before 2/27/17. All other deadlines shall be extended accordingly. Signed by Magistrate Judge Peggy A. Leen on 2/22/17. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:16-cv-02018-RFB-PAL Document 20 Filed 02/17/17 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]

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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,
Plaintiff,

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v.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,

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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
(Third Extension Request)

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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
extension of time to file Defendant’s Notice Of Voluntary Remand Of The Case or Cross-Motion To
Affirm by one week from the current deadline of February 20, 2017 to February 27, 2017, with all

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Case 2:16-cv-02018-RFB-PAL Document 20 Filed 02/17/17 Page 2 of 4

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other dates in this Court’s Order Concerning Review Of Social Security Cases extended accordingly.

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This is Defendant’s third request for an extension.

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Good cause exists to grant Defendant’s request for extension. Counsel needs additional time to

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make time for the agency’s review process for new attorneys, which requires additional levels of

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review. Due to scheduling conflicts and the upcoming President’s Day holiday, Counsel will not be
able to complete the agency’s review process in time for the current deadline.

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Case 2:16-cv-02018-RFB-PAL Document 20 Filed 02/17/17 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 17th day of February 2017,

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Date:

February 17, 2017
By:

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Date:

February 17, 2017

/s/*Howard Olinsky
Howard D. Olinsky
*by email authorization on 2/17/17
Attorney for Plaintiff
DANIEL G. BOGDEN
United States Attorney
HOLLY A. VANCE
Assistant United States Attorney

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By:
/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant United States Attorney

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[PROPOSED] ORDER
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

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27, 2017. All other deadlines shall be extended accordingly.

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IT IS SO ORDERED.

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February 22, 2017
Dated: _____________

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THE HONORABLE PEGGY A. LEEN
United States Magistrate Judge

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Case 2:16-cv-02018-RFB-PAL Document 20 Filed 02/17/17 Page 4 of 4

CERTIFICATE OF SERVICE

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I, TINA L. NAICKER, 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 17th day of February 2017,

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/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant United States Attorney

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Attorney for Defendant

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