Castle v. Colvin

Filing 18

ORDER Granting 17 Stipulation to Extend Time to File Motion for Reversal and/or Remand. See Order for deadlines. Signed by Magistrate Judge George Foley, Jr on 3/9/17. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:16-cv-02412-GMN-GWF Document 17 Filed 03/08/17 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: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiff
JASON S. CASTLE

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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JASON S. CASTLE
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-02412-GMN-GWF
STIPULATION TO EXTEND TIME
TO FILE MOTION FOR REVERSAL
AND/OR REMAND
(FIRST REQUEST)

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Plaintiff Jason S. Castle and Defendant Nancy A. Berryhill, Acting

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Commissioner of Social Security, through their undersigned attorneys, stipulate,
subject to this court’s approval, to extend the time to April 27, 2017 for Plaintiff to
file Plaintiff’s Motion for Reversal and/or Remand; and that Defendant shall have
until May 29, 2017, to file her opposition, if any is forthcoming. Any reply by
plaintiff will be due June 19, 2017.
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Case 2:16-cv-02412-GMN-GWF Document 17 Filed 03/08/17 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-02412-GMN-GWF Document 17 Filed 03/08/17 Page 3 of 4

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DATE: March 8, 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. Jason S. Castle

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DATE: March 8, 2017

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Daniel G. Bogden
United States Attorney

/s/ Hay-Mie Cho

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BY: ____________________________
Hay-Mie Cho
Special Assistant United States Attorney
Attorneys for defendant Nancy A. Berryhill
|*authorized by e-mail|

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DATED: March 9, 2017
IT IS SO ORDERED:
UNITED STATES MAGISTRATE JUDGE

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Case 2:16-cv-02412-GMN-GWF Document 17 Filed 03/08/17 Page 4 of 4

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CERTIFICATE OF SERVICE
FOR CASE NUMBER 2:16-CV-02412-GMN-GWF

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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 8, 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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