Opinion
2:22-cv-01781-VCF
07-05-2023
MIRA KHANY, Plaintiff, v. KILOLO KIJAKAZI, Acting Commissioner of Social Security, Defendant.
JASON M. FRIERSON United States Attorney ZACHARY BERKOFF-CANE Special Assistant United States Attorney
JASON M. FRIERSON United States Attorney
ZACHARY BERKOFF-CANE Special Assistant United States Attorney
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. 19), currently due on July 5, 2023, by 30 days, through and including August 4, 2023. Defendant further requests that all subsequent deadlines set forth in the Court's scheduling order be extended accordingly.
This is Defendant's first request for an extension of time. Good cause exists for this extension due to Defendant's counsel's workload as described below. Since Plaintiff's motion was filed on June 5, 2023, Defendant's counsel has completed five briefs in other matters. Defendant's counsel has another eight briefs due in the next thirty days.
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 June 30, 2023, counsel for Defendant conferred with Plaintiff's attorney, 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 August 4, 2023.
IT IS SO ORDERED: