Opinion
2:22-cv-01119-DJA
02-24-2023
DOLLY STODDART, Plaintiff, v. KILOLO KIJAKAZI, Acting Commissioner of Social Security, Defendant.
JASON M. FRIERSON, Nevada Bar No. 7709, United States Attorney, District of Nevada, RYAN LU, Oregon Bar No. #105902, 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, Nevada Bar No. 7709, United States Attorney, District of Nevada, RYAN LU, Oregon Bar No. #105902, 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 (THIRD 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), currently due on February 27, 2023, by 14 days, through and including March 13, 2023. Defendant further requests that all subsequent deadlines set forth in the Court's scheduling order (Dkt. No. 26) be extended accordingly.
This is Defendant's third 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. On January 30, 2023, Defendant's counsel moved for a 28-day extension for the purpose of exploring settlement options in this case and consult and negotiate with Plaintiff's counsel, as required. The Court granted Defendant's motion for extension. Dkt. No. 26. However, Defendant's counsel is currently still in the process of exploring settlement options and needs more time to receive a response from the client agency. If settlement is not possible, Defendant's counsel will need time to draft and file Defendant's responsive brief. This request is made in good faith and with no intention to unduly delay the proceedings, and counsel apologizes for the inconvenience this delay has caused the Court and Plaintiff.
On February 24, 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 March 13, 2023.