Opinion
CIVIL 2:23-cv-01008-VCF
10-16-2023
DESTINEE PRICE, Plaintiff, v. KILOLO KIJAKAZI, Acting Commissioner of Social Security, Defendant.
JASON M. FRIERSON United States Attorney District of Nevada Nevada Bar No. 7709 MICHONNE L. OMO (IL 6309833) Special Assistant United States Attorney Office of Program Litigation, Office 7 Office of the General Counsel Social Security Administration Attorneys for Defendant
JASON M. FRIERSON United States Attorney District of Nevada Nevada Bar No. 7709 MICHONNE L. OMO (IL 6309833) Special Assistant United States Attorney Office of Program Litigation, Office 7 Office of the General Counsel Social Security Administration Attorneys for Defendant
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO MOTION TO REMAND (FIRST REQUEST)
Defendant, Kilolo Kijakazi, Acting Commissioner of Social Security (the “Commissioner”), by and through her undersigned attorneys, hereby moves for a 45-day extension of time to file her response to Plaintiff's motion to remand. The response is due to be filed by October 20, 2023. This is the Commissioner's first request for an extension of time to file the response.
Defendant submits that good cause exists for this extension request because the attorney tasked with writing the response has several concurrent deadlines, and needs sufficient time to review the record, evaluate the issues raised in Plaintiff's motion to remand, and prepare Defendant's response. 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. Accordingly, Defendant requests an extension in which to respond to file the response until December 4, 2023.
The undersigned conferred with Plaintiff's counsel, who confirmed on October 16, 2023, that Plaintiff has no objection to the requested extension.
It is therefore respectfully requested that Defendant be granted an extension of time to file the response to Plaintiff's motion to remand, through and including December 4, 2023.
IT IS SO ORDERED: