Opinion
2:22-cv-01053-BNW
11-15-2022
ALBERT L. THOMBS, Plaintiff, v. KILOLO KIJAKAZI, Acting Commissioner of Social Security, Defendant.
JASON M. FRIERSON United States Attorney MARGARET BRANICK-ABILLA Special Assistant United States Attorney Attorneys for Defendant
JASON M. FRIERSON United States Attorney MARGARET BRANICK-ABILLA Special Assistant United States Attorney Attorneys for Defendant
UNOPPOSED MOTION FOR EXTENSION OF TIME (FIRST REQUEST)
Defendant Kilolo Kijakazi, Acting Commissioner of Social Security (the “Commissioner”), through her undersigned counsel, hereby requests a 60 day extension of time, from November 21, 2022 to January 20, 2023, to file her Cross-Motion to Affirm and Response to Plaintiff's Motion for Reversal and/or Remand in this case.
This is the Commissioner's first request for an extension. Due to ongoing staffing fluctuations and organizational changes, the undersigned counsel for the Commissioner has been tasked with handling additional cases, delivering attorney training, overseeing other attorneys, and serving as a jurisdictional coordinator. The undersigned is also responsible for over 90 District Court or Ninth Circuit cases, several of which require imminent briefing. Additionally, the undersigned will be serving as caretaker for an aged parent during the holidays. The Commissioner's counsel therefore needs additional time in the instant case to review the administrative record, to consider the issues that Plaintiff has raised, and to prepare the Commissioner's portions of the joint submission.
On November 14, 2022, counsel for the Commissioner conferred with Plaintiff's counsel, who has no opposition to this motion.
WHEREFORE, Defendant requests until January 20, 2023, to file her Cross-Motion to Affirm and Response to Plaintiff's Motion for Reversal and/or Remand.
IT IS SO ORDERED: