Opinion
2:21-cv-01237-EJY
01-27-2022
EDNA CALLAWAY, Plaintiff, v. KILOLO KIJAKAZI, Acting Commissioner of Social Security, Defendant.
CHRISTOPHER CHIOU Acting United States Attorney District of Nevada Nevada Bar No. 14853 ALLISON J. CHEUNG, CSBN 244651 Special Assistant United States Attorney Attorneys for Defendant
CHRISTOPHER CHIOU Acting United States Attorney District of Nevada Nevada Bar No. 14853 ALLISON J. CHEUNG, CSBN 244651 Special Assistant United States Attorney Attorneys for Defendant
UNOPPOSED MOTION FOR EXTENSION OF TIME
Defendant, the Acting Commissioner of Social Security, through the undersigned counsel, hereby requests a 30-day extension of time to respond to Plaintiff's Motion for Reversal and/or Remand, which is currently due on or before February 2, 2022. The new proposed deadline is March 4, 2022.
This is Defendant's first request for an extension of time. Good cause exists for this extension because Defendant's counsel is in the process of conferring with her client to determine whether this matter can be resolved by settlement. The additional requested time will allow for settlement discussions with Plaintiff's counsel once the undersigned has conferred with her client, and if the matter cannot be resolved, to allow counsel to prepare a response to the pending 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 January 25, 2022, the undersigned conferred with Plaintiff's counsel, who has no opposition to the requested extension.
It is therefore respectfully requested that Defendant be granted a 30-day extension of time to file a response to Plaintiff's Motion for Reversal and/or Remand, through and including March 4, 2022.