Opinion
3:21-cv-0357-CLB
01-24-2022
LARONDA WOODS, Plaintiff, v. KILOLO KIJAKAZI, Acting Commissioner of Social Security, [1] Defendant.
CHRISTOPHER CHIOU Acting United States Attorney District of Nevada Nevada Bar No. 14853 SATHYA OUM, CSBN 255431 Special Assistant United States Attorney
CHRISTOPHER CHIOU Acting United States Attorney District of Nevada Nevada Bar No. 14853
SATHYA OUM, CSBN 255431 Special Assistant United States Attorney
MOTION FOR EXTENSION OF TIME TO FILE CERTIFIED ADMINISTRATIVE RECORD AND ANSWER (SECOND REQUEST)
Defendant, Kilolo Kijakazi, Acting Commissioner of Social Security (the “Commissioner”), by and through her undersigned attorneys, hereby moves for a 7-day extension of time to file the Certified Administrative Record (CAR) and answer to Plaintiffs Complaint. The CAR and answer to Plaintiffs Complaint are due to be filed by January 24, 2022. This is the Commissioner's second request for an extension of time.
Defendant makes this request in good faith and with no intention to delay proceedings unnecessarily. While the Answer and CAR are ready to be filed, the CD copies of the CAR that must be sent to the Pro-Se Plaintiff are not yet prepared. The undersigned was out sick for two weeks and did not provide enough notice to have the CD copies prepared. As such, she requests that this Court grant an additional week to have the CDs prepared and sent to the U.S. Attorney's office, who will then send the CDs to Plaintiff.
The undersigned is unable to reach Plaintiff.
It is therefore respectfully requested that Defendant be granted an extension of time to file the CAR and answer to Plaintiffs Complaint, through and including January 31, 2022.
IT IS SO ORDERED:
CERTIFICATE OF SERVICE
I, the undersigned, am a citizen of the United States and am at least eighteen years of age. My business address is 160 Spear Street, Suite 800, San Francisco, California 94105. I am not a party to the above-entitled action. On the date set forth below, I caused service of UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE CERTIFIED ADMINISTRATIVE RECORD AND ANSWER; DECLARATION OF JEBBY RASPUTNIS by electronically filing the foregoing with the Clerk of the District Court using its ECF System and by U.S. Mail to the following:
LaRonda Woods 4110 Rio Poco Rd. Reno, NV 89502
I declare under penalty of perjury that the foregoing is true and correct.