Opinion
2:22-cv-01201-VCF
01-12-2023
OSLAIDA CRUZ DE OSES, Plaintiff, v. KILOLO KIJAKAZI, Commissioner of Social Security, Defendant.
JASON M. FRIERSON, DAVID PRIDDY Special Assistant United States Attorney. Leonard Stone, Shook & Stone, Chtd., Marc V. Kalagian, Law Offices of Lawrence D. Rohlfing, Inc., CPC Attorneys for Plaintiff.
JASON M. FRIERSON, DAVID PRIDDY Special Assistant United States Attorney.
Leonard Stone, Shook & Stone, Chtd., Marc V. Kalagian, Law Offices of Lawrence D. Rohlfing, Inc., CPC Attorneys for Plaintiff.
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. 23, filed on December 14, 2022), currently due on January 13, 2023, by 31 days, through and including February 13, 2023. Defendant further requests that all subsequent deadlines set forth in the Court's scheduling order (Dkt. No. 22) be extended accordingly. Plaintiff's optional reply shall therefore be due on March 6, 2023.
This is Defendant's first request for an extension of time to file a response. Good cause exists for this extension. Defendant respectfully requests this additional time because counsel is currently in the process of determining if a settlement agreement is possible. If the case cannot be settled, then Defendant's counsel will proceed with filing Defendant's response to Plaintiff's Motion to Reversal and/or Remand. This request is made in good faith and with no intention to unduly delay the proceedings.
On January 12, 2023, counsel for Defendant conferred with Plaintiff's counsel, who has no opposition to this motion.
It is therefore requested that Defendant be granted an extension of time to respond to Plaintiff's Motion for Reversal and/or Remand, through and including February 13, 2023.
IT IS SO ORDERED: