Opinion
3:23-cv-00072-CLB
08-17-2023
MICHELLE THOMAS, Plaintiff, v. KILOLO KIJAKAZI, Acting Commissioner of Social Security, Defendant.
JASON M. FRIERSON United States Attorney Nevada Bar No. 7709 MICHAEL J. MULLEN Special Assistant United States Attorney Washington Bar No. 54288 Office of the General Counsel Social Security Administration Attorneys for Defendant
JASON M. FRIERSON United States Attorney Nevada Bar No. 7709 MICHAEL J. MULLEN Special Assistant United States Attorney Washington Bar No. 54288 Office of the General Counsel Social Security Administration Attorneys for Defendant
ORDER GRANTING UNOPPOSED MOTION FOR EXTENSION OF TIME (FIRST REQUEST)
Defendant, the Commissioner of Social Security, respectfully requests that the Court extend the time for Defendant to respond to Plaintiff's Motion for Reversal and/or Remand (Dkt. No. 19, filed on July 19, 2023), currently due on August 18, 2023, by 35 days, through and including September 22, 2023. Defendant further requests that all subsequent deadlines be extended accordingly.
This is Defendant's first request for an extension of time. Good cause exists for this extension due to Defendant's counsel's workload, as described below. In the span of four workdays, Defendant's counsel has six briefing deadlines, including this matter. In August 2023, counsel has completed numerous other briefing assignments. Although counsel has exercised due diligence, the requested additional time is necessary.
Additional time is required to review the record, to evaluate the issues raised in Plaintiff's motion, to determine whether options exist for settlement, and if not, to prepare Defendant's response to Plaintiff's motion. Defendant's counsel will endeavor to complete these tasks as soon as possible. This request is made in good faith and with no intention to unduly delay the proceedings, and counsel apologizes for any inconvenience.
On August 17, 2023, counsel for Defendant conferred with Plaintiff's counsel, 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 September 22, 2023.
ORDER
No further extensions of time will be granted absent extraordinary circumstances.
IT IS SO ORDERED.