Bartz v. Colvin
Filing
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ORDER Granting 18 Stipulation to Extend Time to File Motion for Reversal and/or Remand. See Order for deadlines. Signed by Judge Richard F. Boulware, II on 3/24/17. (Copies have been distributed pursuant to the NEF - ADR)
Case 2:16-cv-02073-RFB-PAL Document 18 Filed 03/23/17 Page 1 of 4
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Marc V. Kalagian
Attorney at Law: 4460
211 East Ocean Boulevard, Suite 420
Long Beach, CA 90802
Tel: (562)437-7006
Fax: (562)432-2935
E-Mail: rohlfing.kalagian@rksslaw.com
Attorneys for Plaintiff
THOMAS M. BARTZ
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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THOMAS M. BARTZ
Plaintiff,
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v.
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NANCY A. BERRYHILL, Acting
Commissioner of Social Security.
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Defendant.
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Case No.: 2:16-cv-02073-RFB-PAL
STIPULATION TO EXTEND TIME
TO FILE MOTION FOR REVERSAL
AND/OR REMAND
(SECOND REQUEST)
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Plaintiff Thomas M. Bartz (“Plaintiff”) and defendant Nancy A. Berryhill,
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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 April 24,
2017; and that Defendant shall have until May 24, 2017, to file her opposition, if
any is forthcoming. Any reply by plaintiff will be due June 14, 2017.
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Case 2:16-cv-02073-RFB-PAL Document 18 Filed 03/23/17 Page 2 of 4
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As the Court is aware, after a 5 year battle with terminal stage 4 cancer
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Plaintiff’s Counsel’s Spouse of the associate, who this matter is assigned to, passed
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away on September 30, 2016. The aftermath of this traumatic event on both
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Counsel and his 9 year old son and 7 year old daughter was immeasurable.
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Compounding the impact of this loss is the fact that Counsel’s spouse was a former
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employee at Counsel’s Law Firm and her death was far reaching in its impact on
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Counsel’s professional life as well. Due to the death, the subsequent holiday
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period, and the need to find a permanent caregiver and the required time to
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acclimate his children to that presence during his absence to meet his professional
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obligations, Counsel requires the additional time to prepare and file her motion for
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summary judgment.
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Counsel for plaintiff does not anticipate this extraordinary request for more
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time to become the rule and recognizes it is the extraordinary exception and
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sincerely apologizes to the court for any inconvenience this may have had upon it
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or its staff.
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Case 2:16-cv-02073-RFB-PAL Document 18 Filed 03/23/17 Page 3 of 4
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DATE: March 23, 2017
Respectfully submitted,
ROHLFING & KALAGIAN, LLP
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/s/ Marc V. Kalagian
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BY: _______________________
Marc V. Kalagian
Attorney for plaintiff Mr. Thomas M. Bartz
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DATE: March 23, 2017
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Daniel G. Bogden
United States Attorney
/s/ Urmila R. Taylor
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BY: ____________________________
Urmila R. Taylor
Special Assistant United States Attorney
Attorneys for defendant Nancy A. Berryhill
|*authorized by e-mail|
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DATED: March 24, 2017
IT IS SO ORDERED:
UNITED STATES DISTRICT JUDGE
UNITED STATES MAGISTRATE JUDGE
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Case 2:16-cv-02073-RFB-PAL Document 18 Filed 03/23/17 Page 4 of 4
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CERTIFICATE OF SERVICE
FOR CASE NUMBER 2:16-CV-02073-RFB-PAL
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I hereby certify that I electronically filed the foregoing with the Clerk of the
Court for this court by using the CM/ECF system on March 23, 2017.
I certify that all participants in the case are registered CM/ECF users and
that service will be accomplished by the CM/ECF system.
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/s/ Marc V. Kalagian
_______________________________
Marc V. Kalagian
Attorneys for Plaintiff
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