Opinion
2:22-cv-01792-VCF
02-02-2023
KELLY JO GOFORTH, Plaintiff, v. KILOLO KIJAKAZI, Acting Commissioner of Social Security, Defendant.
JASON M. FRIERSON UNITED STATES ATTORNEY OSCAR GONZALEZ DE LLANO SPECIAL ASSISTANT UNITED STATES ATTORNEY
JASON M. FRIERSON UNITED STATES ATTORNEY
OSCAR GONZALEZ DE LLANO SPECIAL ASSISTANT UNITED STATES ATTORNEY
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE CERTIFIED ADMINISTRATIVE RECORD AND ANSWER; [PROPOSED] ORDER
(FIRST REQUEST)
Defendant, Kilolo Kijakazi, Commissioner of Social Security (the “Commissioner”), by and through the undersigned attorneys, hereby moves for a thirty-day extension of time to file the Certified Administrative Record (CAR) and answer to Plaintiff's Complaint. The CAR and answer to Plaintiff's Complaint are due to be filed by February 2, 2023.
The certified administrative record (CAR) in this case has not been finalized for filing. The agency's Office of Appellate Operations (OAO) is responsible for preparation of CARs. Counsel for the Commissioner is in contact with OAO to ensure that the CAR is properly certified for filing. OAO has indicated it needs additional time to prepare the CAR. Counsel for the Commissioner has consulted with Plaintiff's counsel who advised that he has no objections to an extension of thirty-days.
This request is made in good faith and is not intended to delay the proceedings in this matter. It is therefore respectfully requested that Defendant be granted an extension of time to file the CAR and answer to Plaintiff's Complaint, through and including March 4, 2023.
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 160 Spear Street, Suite 800, San Francisco, California 94105. I am not a party to the above-entitled action. On the date set forth below, I caused service of UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE CERTIFIED ADMINISTRATIVE RECORD AND ANSWER; [PROPOSED] ORDER on the following parties by electronically filing the foregoing with the Clerk of the District Court using its ECF System, which provides electronic notice of the filing:
Leonard Stone
Shook & Stone, Chtd.
710 S Fourth Street
Las Vegas, NV 89101
Email: lstone@shookandstone.com
Marc V. Kalagian
Law Offices of Lawrence D. Rohlfing, Inc., CPC 12631 East Imperial Highway, Suite C115
Santa Fe Springs, CA 90670
Email: marc.kalagian@rksslaw.com
I declare under penalty of perjury that the foregoing is true and correct.
Dated: February 2, 2023
[PROPOSED] ORDER GRANTING EXTENSION OF TIME
Based upon Defendant's Motion for Extension of Time to File Certified Administrative Record and Answer, and for good cause shown, IT IS ORDERED that the date on which Defendant's answer is due is extended by thirty days, from February 2, 2023 to March 4, 2023. Defendant shall file the answer on or before March 4, 2023.
IT IS SO ORDERED.