Opinion
2:23-cv-00725-BNW
07-06-2023
ALEXANDRA BALLEZA KNEELAND - ANDREWS, Plaintiff, v. KILOLO KIJAKAZI, Acting Commissioner of Social Security, Defendant.
JASON M. FRIERSON United States Attorney Nevada Bar No. 7709 OSCAR GONZALEZ DE LLANO, DCBN 491042 Special Assistant United States Attorney Social Security Administration Office of the General Counsel Attorneys for Defendant JASON M. FRIERSON United States Attorney Oscar Gonzalez de Llano Special Assistant United States Attorney
JASON M. FRIERSON United States Attorney Nevada Bar No. 7709 OSCAR GONZALEZ DE LLANO, DCBN 491042 Special Assistant United States Attorney Social Security Administration Office of the General Counsel Attorneys for Defendant
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 (FIRST REQUEST)
Defendant, Kilolo Kijakazi, Acting 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 July 7, 2023.
The 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. Despite diligent efforts OAO has indicated it still needs additional time to prepare the CAR. OAO has recently been dealing with some staff shortages, changes in their processes and a surge of new filings which has led to some delays in production of CARs. Counsel for the Commissioner has consulted with Plaintiff's counsel who advised that he has no objections to an extension of thirty days. The Commissioner asks for this extension with the understanding that if the CAR becomes available to the Office of the General Counsel before the requested date, the record will be filed earlier when feasible.
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 August 6, 2023.
IT IS SO ORDERED.