Opinion
Defendant. 2:22-cv-01222-VCF
12-08-2022
JEFFREY LYNN HOLTAN, Plaintiff, v. KILOLO KIJAKAZI, Acting Commissioner of Social Security, Defendant.
JASON M. FRIERSON, JULIE A.K. CUMMINGS, Attorneys for Defendant.
JASON M. FRIERSON, JULIE A.K. CUMMINGS, Attorneys for Defendant.
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. 20), currently due on December 12, 2022, by 30 days, through and including January 11, 2023. Defendant further requests that all subsequent deadlines set forth in the Court's scheduling order (Dkt. No. 17) be extended accordingly.
This is Defendant's first request for an extension of time. Good cause exists for this extension for the following reasons. The undersigned attorney for Defendant (Julie A.K. Cummings) was just this week reassigned this case due to the pressing workload of her colleague, Michonne Omo. The undersigned cannot complete the brief in the present case by December 12, 2022, due to her own full caseload. Specifically, the undersigned presently has 25 pending matters at various stages of litigation and requires additional time to sequence the newly reassigned case into her schedule.
Additional time is required to review the record, to evaluate the numerous 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 December 6, 2022, counsel for Defendant conferred with Marc V. Kalagian, counsel Plaintiff, 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 January 11, 2023.
IT IS SO ORDERED: