Opinion
2:22-cv-01663-DJA
04-21-2023
JILL REBECCA CUEVAS, Plaintiff, v. KILOLO KIJAKAZI, Acting Commissioner of Social Security, Defendant.
JASON M. FRIERSON, Nevada Bar No. 7709 United States Attorney SOHAYL VAFAI, California Bar No. 319266 Special Assistant United States Attorney Office of the General Counsel Attorneys for Defendant
JASON M. FRIERSON, Nevada Bar No. 7709 United States Attorney SOHAYL VAFAI, California Bar No. 319266 Special Assistant United States Attorney Office of the General Counsel Attorneys for Defendant
UNOPPOSED MOTION FOR EXTENSION OF TIME (FIRST REQUEST)
Defendant Kilolo Kijakazi, Acting Commissioner of Social Security (Commissioner), respectfully moves this Court for a 30-day extension of time to file her cross-motion to affirm in this case, changing the date on which the cross-motion is due from May 1, 2023, to May 31, 2023. This is Defendant's first request for an extension of the deadline to file the cross-motion. Defendant conferred with counsel for Plaintiff, who confirmed that Plaintiff does not object to the request.
In support of this motion, the Commissioner respectfully states as follows:
1. Good cause for an extension exists because the Commissioner requires additional time to review the defensibility of this case. An extended deadline would allow Plaintiff time to consider any remand offer and the parties to negotiate the terms of any remand offer. An extension would also provide Defendant adequate time to draft a cross-motion to affirm if the parties cannot agree to a voluntary remand.
2. Thus, Defendant requests an extension of 30 days, until May 31, 2023, to file the crossmotion to affirm.
3. This request is made in good faith and is not intended to delay the proceedings in this matter.
For the foregoing reasons, Defendant respectfully requests until May 31, 2023, to file the cross-motion to affirm.
Dated: April 21, 2023 Respectfully submitted, JASON M. FRIERSON United States Attorney
SOHAYL VAFAI Special Assistant United States Attorney
IT IS SO ORDERED
CERTIFICATE OF SERVICE
I, the undersigned, am a citizen of the United States and am at least eighteen years of age. My business address is 6401 Security Boulevard, Baltimore, MD 21235. I am not a party to the aboveentitled action. On the date set forth below, I caused a copy of the above UNOPPOSED MOTION FOR EXTENSION OF TIME ( FIRST REQUEST ) to be served upon the following by:
CM/ECF:
Daniel H. Fishman
dan@ssihelp.us
Hal Taylor
haltaylorlawyer@gbis.com
I declare under penalty of perjury that the foregoing is true and correct.