Opinion
2:23-cv-00956-NJK
10-19-2023
ALISON B BCOCK Plaintiff, v. KILOLO KIJAKAZI, Acting Commissioner of Social Security, Defendant.
JASON M. FRIERSON United States Attorney JAMES KI Special Assistant United States Attorney
JASON M. FRIERSON United States Attorney
JAMES KI Special Assistant United States Attorney
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. 11), currently due on October 19, 2023, by 29 days, through and including November 17, 2023. Defendant further requests that all subsequent deadlines set forth in the Court's scheduling order be extended accordingly.
This is Defendant's first request for an extension of time for briefing. Good cause exists for this extension as Defendant needs additional time to explore settlement options. Since Plaintiff's motion was filed on September 19, 2023, Defendant's counsel has filed five briefs in other matters and negotiated settlement in a sixth case.
Additional time is required to review the record, to evaluate the 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 October 17, 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 November 17, 2023.
IT IS SO ORDERED: