Opinion
Civil 2:22-cv-01781-VCF
04-03-2023
MIRA KHANY, Plaintiff v. KILOLO KIJAKAZI, Acting Commissioner Social Security, Defendant.
Joshua R. Harris, Esquire Nevada Bar No. 9580 Richard Harris Law Firm Joshua R. Harris, Esquire Nevada Bar No. 9580 Richard Harris Law Firm Attorney for Plaintiff, Mira Khany
Joshua R. Harris, Esquire Nevada Bar No. 9580 Richard Harris Law Firm
Joshua R. Harris, Esquire Nevada Bar No. 9580 Richard Harris Law Firm Attorney for Plaintiff, Mira Khany
PLAINTIFF'S UNOPPOSED MOTION FOR A THIRTY (30) DAY EXTENSION TO FILE PLAINTIFF'S MOTION FOR REMAND TO AGENCY AND MEMORANDUM IN SUPPORT ON OR BEFORE MAY 1, 2023
Cam Ferenbach, United States Magistrate Judge
COMES NOW Plaintiff, Mira Khany, through her undersigned counsel, and moves this Court for an extension of time of thirty (30) days to file Plaintiff's Motion for Remand to Agency and Memorandum in Support on or before May 1, 2023.
1. Plaintiff's counsel has recently seen a significant increase in disability matters that have been initiated in Federal District Court.
2. Due to the recent increase in Disability matters that have been initiated and Federal District Court and the recent changes under the updated F.R.C.P 7.1, Supplemental Rules for Social Security Actions under 42 U.S.C. §405(g), the undersigned has seen a lot of federal court opening Memorandums all coming due at the same time.
3. The undersigned does not wish to have his workload affect the interests of this severely disabled plaintiff.
4. The case before this Court is an important one that deserves proper and complete briefing by the parties. The additional time shall allow the undersigned to properly bring forth all of the issues in this matter.
5. There is no indication that granting the Plaintiff's Motion for Extension would result in any prejudice to the Defendant. In fact, counsel for SSA has indicated that they do not object to Plaintiff's request for additional time.
WHEREFORE, Plaintiff's moves this Court for an Order granting Plaintiff an additional thirty (30) days to file Plaintiff's Motion for Remand to Agency and Memorandum in Support on or before May 1, 2023.
IT IS SO ORDERED.
CERTIFICATE OF SERVICE
I hereby certify that on March 31, 2023, a copy of the foregoing Plaintiff's Motion for Extension has been electronically filed and is available for viewing and downloading from the Electronic Case Filing system of this Court. The Social Security Administration's Office of the General Counsel and the United States Attorney's Office are registered to receive electronic service with the Electronic Case Filing system of this Court. Therefore, SSA and its counsel have been fully served and nothing further is required.
PLAINTIFF'S UNOPPOSED MOTION FOR A THIRTY (30) DAY EXTENSION TO FILE PLAINTIFF'S MOTION FOR REMAND TO AGENCY AND MEMORANDUM IN SUPPORT ON OR BEFORE MAY 1, 2023
Upon consideration of Plaintiff's Unopposed Motion for a Thirty (30) Day Extension to file Plaintiff's Motion for Remand to Agency and Memorandum in Support, it is hereby ORDERED that Plaintiff's Motion is GRANTED. Plaintiff shall file her Motion for Remand to Agency and Memorandum in Support on or before May 1, 2023.
SO ORDERED