Opinion
2:22-cv-00571-VCF
08-04-2022
LISA THOMAS, Plaintiff, v. KILOLO KIJAKAZI, Acting Commissioner of Social Security, Defendant.
JASON M. FRIERSON UNITED STATES ATTORNEY ALLISON J. CHEUNG ALLISON J. CHEUNG SPECIAL ASSISTANT UNITED STATES ATTORNEY
JASON M. FRIERSON
UNITED STATES ATTORNEY
ALLISON J. CHEUNG
ALLISON J. CHEUNG
SPECIAL ASSISTANT UNITED STATES ATTORNEY
UNOPPOSED MOTION FOR EXTENSION OF TIME (FIRST REQUEST)
Defendant, the Acting Commissioner of Social Security, through the undersigned counsel, hereby requests a 30-day extension of time to respond to Plaintiff's Motion for Reversal and/or Remand, which is currently due on or before August 31, 2022. The new proposed deadline is September 30, 2022.
Good cause exists for this request because the undersigned attorney and Defendant's counsel of record has resigned from the Office of the General Counsel for the Social Security Administration, and is currently transitioning her matters to other attorneys. Additional time is required so that the new attorney has time to review Plaintiff's motion and case file in order to determine whether this matter can be resolved by settlement, or whether the Commissioner will respond by filing an answering brief. This request is made in good faith and is not intended to delay the proceedings in this matter. Counsel apologizes to the Court and Plaintiff's counsel for the inconvenience.
On August 3, 2022, the undersigned conferred with Plaintiff's counsel, who has no opposition to the requested extension.
It is therefore respectfully requested that Defendant be granted a 30-day extension of time to file a response to Plaintiff's Motion for Reversal and/or Remand, through and including September 30, 2022.
IT IS SO ORDERED.