Shane v. Colvin

Filing 24

ORDER Granting 23 Stipulation to Extend Time re 19 Motion to Remand. (Responses due by 8/20/2017.) Signed by Magistrate Judge Carl W. Hoffman on 7/24/17. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:16-cv-02263-CWH Document 23 Filed 07/21/17 Page 1 of 4

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Marc V. Kalagian (NSBN 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]
Gerald M. Welt Attorney at Law (NSBN 1575)
732 S. Sixth Street, Suite 200-D
Las Vegas, NV 89101
Tel.: [phone]
Fax: [phone]
E-mail: [e-mail]; [e-mail]

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Attorneys for Plaintiff
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STEVEN W. MYHRE (NSBN 9635)
Acting United States Attorney
District of Nevada
TINA L. NAICKER, CSBN 252766
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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MICHAEL SHANE,
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Plaintiff,
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v.
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NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Case No. 2:16-CV-02263-CWH
JOINT STIPULATION FOR EXTENSION OF
TIME TO FILE DEFENDANT’S NOTICE OF
VOLUNTARY REMAND OF THE CASE OR
CROSS-MOTION TO AFFIRM
(Second Request)

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Case 2:16-cv-02263-CWH Document 23 Filed 07/21/17 Page 2 of 4

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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that
the time for responding to Plaintiff’s Motion for Summary Judgment be extended for approximately
thirty (30) days from July 21, 2017 to August 20, 2017. This is Defendant’s second request for

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extension. Good cause exists to grant Defendant’s request for extension. Counsel for Defendant was
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involved in a car accident on Wednesday, July 19, 2017 and had to take unanticipated medical leave.

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Counsel for Defendant apologizes for the belated nature of the request, but did not anticipate taking

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medical leave resulting from her car accident. Additional time is also required as counsel for

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Defendant has over 50+ active matters, of which two dispositive motions are required until mid-

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August. Counsel respectfully requests additional time to respond to Plaintiff’s Motion for Summary
Judgment in order to adequately research, analyze and respond to the issues presented by Plaintiff.

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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 to the requested relief.

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Case 2:16-cv-02263-CWH Document 23 Filed 07/21/17 Page 3 of 4

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The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly.

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Respectfully submitted,

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Date:

July 21, 2017
By:

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Date:

July 21, 2017

/s/ Cyrus Safa
CYRUS SAFA for Marc Kalagian
*by email authorization on 7/21/17
Attorney for Plaintiff
STEVEN W. MYHRE
Acting United States Attorney

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

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IT IS SO ORDERED.

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DATE:

July 24, 2017
THE HONORABLE CARL W. HOFFMAN
United States Magistrate Judge

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Case 2:16-cv-02263-CWH Document 23 Filed 07/21/17 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

3 JOINT STIPULATION FOR EXTENSION OF TIME TO FILE DEFENDANT’S NOTICE OF
4 VOLUNTARY REMAND OF THE CASE OR CROSS-MOTION TO AFFIRM
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on the date and via the method of service identified below:

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CM/ECF:
Marc V. Kalagian (NSBN 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]
Gerald M. Welt Attorney at Law (NSBN 1575)
732 S. Sixth Street, Suite 200-D
Las Vegas, NV 89101
Tel.: [phone]
Fax: [phone]
E-mail: [e-mail]; [e-mail]
Attorneys for Plaintiff
MICHAEL SHANE
Respectfully submitted this 21st day of July 2017,

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

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