Opinion
2:22-cv-00420-VCF
08-02-2022
CHARLIE YOUNG, Plaintiff, v. KILOLO KIJAKAZI, Acting Commissioner of Social Security, Defendant.
JASON M. FRIERSON, United States Attorney, Nevada Bar No. 7709, ALLISON J. CHEUNG, CSBN 244651, Special Assistant United States Attorney, Attorneys for Defendant.
JASON M. FRIERSON, United States Attorney, Nevada Bar No. 7709, ALLISON J. CHEUNG, CSBN 244651, Special Assistant United States Attorney, Attorneys for Defendant.
UNOPPOSED MOTION FOR EXTENSION OF TIME
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 8, 2022. The new proposed deadline is September 7, 2022.
This is Defendant's first request for an extension of time. Good cause exists for this extension due to workload of the undersigned attorney. Since Plaintiff's motion was filed, the undersigned attorney has worked on more than 30 cases at various stages of litigation, including numerous responsive briefs that were or are due before August 8. 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 July 29, 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 7, 2022.
IT IS SO ORDERED: