Opinion
2:23-cv-00365-DJA
07-06-2023
JACK CHRISTOPHER SCOTT II, Plaintiff, v. KILOLO KIJAKAZI, Acting Commissioner of Social Security, Defendant. v.
JASON M. FRIERSON, NVSBN 7709 United States Attorney District of Nevada DAVID PRIDDY, ILSBN 6313767 Special Assistant United States Attorney Attorneys for Defendant
JASON M. FRIERSON, NVSBN 7709 United States Attorney District of Nevada DAVID PRIDDY, ILSBN 6313767 Special Assistant United States Attorney 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 to Remand (Dkt. No. 12, filed on June 7, 2023), currently due on July 7, 2023, by 45 days, through and including August 21, 2023. Defendant further requests that all subsequent deadlines be extended accordingly. This is Defendant's first request for an extension of time to file a response.
Good cause exists for this extension. Defendant respectfully requests this additional time because Defendant's counsel is experiencing an extremely heavy workload, despite due diligence. In addition to this case, the undersigned is preparing the Commissioner's response briefs for multiple district court cases with concurrent deadlines. The undersigned currently has five district court briefs due within one week surrounding the current due date of the response brief in this case. For this reason, Defendant's counsel requires additional time to properly address the issues raised in Plaintiff's Motion to Remand. This request is made in good faith and with no intention to unduly delay the proceedings.
Counsel for Defendant advised counsel for Plaintiff of the need for this extension on July 5, 2023. Counsel for Plaintiff confirmed that Plaintiff does not object to this request.
It is therefore requested that Defendant be granted an extension of time to respond to Plaintiff's Motion to Remand, through and including August 21, 2023.