Opinion
2:23-cv-00196-BNW
07-25-2023
MYRA R. ANZALDO, Plaintiff, v. KILOLO KIJAKAZI, Acting Commissioner of Social Security, Defendant.
JASON M. FRIERSON United States Attorney Nevada Bar No. 7709 ZACHARY BERKOFF-CANE, WSBN 47988 Special Assistant United States Attorney Office of the General Counsel Social Security Administration Attorneys for Defendant
JASON M. FRIERSON
United States Attorney
Nevada Bar No. 7709
ZACHARY BERKOFF-CANE, WSBN 47988
Special Assistant United States Attorney
Office of the General Counsel
Social Security Administration
Attorneys for Defendant
UNOPPOSED MOTION FOR EXTENSION OF TIME (FIRST REQUEST)
Defendant Kilolo Kijakazi, Acting Commissioner of Social Security (Defendant) respectfully requests that the Court extend the time for Defendant to respond to Plaintiff's Motion for Reversal and/or Remand (Dkt. No. 18), currently due on July 31, 2023, by 30 days, through and including August 30, 2023. Defendant further requests that all subsequent deadlines be extended accordingly.
This is Defendant's first request for an extension of time. Good cause exists for this extension due to Defendant's counsel's workload as described below. Defendant's counsel has completed five briefs in the past thirty days, and has another seven district court briefs and one Ninth Circuit brief pending in the next thirty days.
Additional time is required to review the record, to evaluate the numerous issues raised in Plaintiff's motion, to determine whether options exist for settlement, and if not, to prepare Defendant's response to Plaintiff's motion. Defendant's counsel will endeavor to complete these tasks as soon as possible. This request is made in good faith and with no intention to unduly delay the proceedings, and counsel apologizes for any inconvenience.
On July 25, 2023, counsel for Defendant conferred with Plaintiff's attorney, who has no opposition to this motion.
It is therefore respectfully requested that Defendant be granted an extension of time to respond to Plaintiff's Motion for Reversal and Remand, through and including August 30, 2023.