Opinion
2:22-cv-01119-DJA
12-20-2022
JASON M. FRIERSON, NVSBN 7709 United States Attorney DAVID PRIDDY, ILSBN 6313767 Special Assistant United States Attorney Attorneys for Defendant
JASON M. FRIERSON, NVSBN 7709
United States Attorney
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 for Reversal and/or Remand (Dkt. No. 21, filed on November 29, 2022), currently due on December 29, 2022, by 32 days, through and including January 30, 2023. Defendant further requests that all subsequent deadlines set forth in the Court's scheduling order (Dkt. No. 20) be extended accordingly.
This is Defendant's first request for an extension of time to file a response. Good cause exists for this extension. The assigned lead attorney of record in this case is unable to complete the briefing before the due date due to an extremely high workload despite due diligence. Defendant requires additional time to transfer this case to another attorney who will have the ability to perform the briefing for this case. This request is made in good faith and with no intention to unduly delay the proceedings, and counsel apologizes for any inconvenience.
On December 16, 2022, counsel for Defendant conferred with Plaintiff's counsel, who has no opposition to this motion.
It is therefore requested that Defendant be granted an extension of time to respond to Plaintiff's Motion for Reversal and/or Remand, through and including January 30, 2023.
IT IS SO ORDERED.