Shane v. Colvin

Filing 15

ORDER Granting 14 Stipulation to Extend Time to File Motion for Remand and/or Reversal. See Order for deadlines. Signed by Magistrate Judge Carl W. Hoffman on 1/24/17. (Copies have been distributed pursuant to the NEF - MR)

Case 2:16-cv-02263-JAD-CWH Document 14 Filed 01/23/17 Page 1 of 3

1
2
3
4
5
6

Marc V. Kalagian
Attorney at Law: 4460
211 East Ocean Boulevard, Suite 420
Long Beach, CA 90802
Tel: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiff
MICHAEL SHANE

7
8
UNITED STATES DISTRICT COURT

9

DISTRICT OF NEVADA

10
11
12

MICHAEL SHANE
Plaintiff,

13

v.

14

NANCY A. BERRYHILL, Acting
Commissioner of Social Security.

15

Defendant.

16
17

)
)
)
)
)
)
)
)
)
)
)

Case No.: 2:16-cv-02263-JAD-CWH
STIPULATION TO EXTEND TIME
TO FILE MOTION FOR REMAND
AND/OR REVERSAL
(FIRST REQUEST)

18
Plaintiff Michael Shane (“Plaintiff”) and defendant Nancy A. Berryhill,

19
20

Acting Commissioner of Social Security (“Defendant”), through their undersigned

21

counsel of record, hereby stipulate, subject to the approval of the Court, to extend

22

the time for Plaintiff to file Plaintiff’s Motion for Reversal and/or Remand to

23

March 9, 2017; and that Defendant shall have 30 days or until April 10, 2017, to

24

file her opposition, if any is forthcoming. Any reply by plaintiff will be due May

25

1, 2017.

26

///

27
28

-1-

Case 2:16-cv-02263-JAD-CWH Document 14 Filed 01/23/17 Page 2 of 3

1

This is Plaintiff's first request for an extension. The Administrative Record

2

provided to Plaintiff’s counsel is unable to be opened and read. Both parties are

3

working to correct this matter. Counsel sincerely apologizes to the court for any

4

inconvenience this may have had upon it or its staff.

5
6

DATE: January 23, 2017

Respectfully submitted,
ROHLFING & KALAGIAN, LLP

7

/s/ Marc V. Kalagian

8

BY: _______________________
Marc V. Kalagian
Attorney for plaintiff Mr. Michael Shane

9
10
11
12

DATE: January 23, 2017

13

Daniel G. Bogden
United States Attorney
/s/ Roya Massoumi

14

BY: ____________________________
Roya Massoumi
Special Assistant United States Attorney
Attorneys for defendant Carolyn W. Colvin
|*authorized by e-mail|

15
16
17
18
19

DATED: January 24, 2017

20

IT IS SO ORDERED:

21

UNITED STATES MAGISTRATE JUDGE

22
23
24
25
26
27
28

-2-

Case 2:16-cv-02263-JAD-CWH Document 14 Filed 01/23/17 Page 3 of 3

1

CERTIFICATE OF SERVICE
FOR CASE NUMBER 2:16-CV-02263-JAD-CWH

2
3
4
5
6

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 January 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.

7
8
9
10

/s/ Marc V. Kalagian
_______________________________
Marc V. Kalagian
Attorneys for Plaintiff

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

-3-