Opinion
2:22-cv-01119-DJA
01-30-2023
DOLLY STODDART, Plaintiff, v. KILOLO KIJAKAZI, Acting Commissioner of Social Security, Defendant.
JASON M. FRIERSON RYAN LU
JASON M. FRIERSON
RYAN LU
UNOPPOSED MOTION FOR EXTENSION OF TIME (FIRST REQUEST) SECOND
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), currently due on January 30, 2023, by 28 days, through and including February 27, 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 second request for an extension of time. Good cause exists for this extension. On January 27, 2023, this case was reassigned to Defendant's lead attorney of record from another attorney at Social Security's Office of the General Counsel. Defendant's counsel is currently exploring settlement options in this case and will need additional time to continue the process and consult and negotiate with Plaintiff's counsel, as required. If settlement is not possible, Defendant's counsel will need time to draft and file Defendant's responsive brief. In the past two weeks, Defendant's lead counsel has worked on several matters with deadlines before or on Defendant's briefing deadline in this case, including drafting and filing four responsive briefs and working and negotiating settlement in two other cases. This request is made in good faith and with no intention to unduly delay the proceedings, and counsel apologizes for any inconvenience.
On January 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 February 27, 2023.
IT IS SO ORDERED: