O'Brien v. Saul

Filing 22

ORDER granting 21 Motion to Extend Time Re: 20 Motion to Remand to Agency. Responses due by 7/16/2021. Signed by Magistrate Judge Brenda Weksler on 6/4/2021. (Copies have been distributed pursuant to the NEF - HAM)

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Case 2:20-cv-01673-BNW Document 21 Filed 06/01/21 Page 1 of 3 1 CHRISTOPHER CHIOU Acting United States Attorney 2 District of Nevada 3 Nevada Bar No. 14853 4 MARGARET LEHRKIND, CSBN 317414 Special Assistant United States Attorney 5 160 Spear Street, Suite 800 San Francisco, California 94105 (510) 970-4829 6 Telephone:(415) 744-0134 Facsimile: 7 E-Mail: margaret.lehrkind@ssa.gov 8 Attorneys for Defendant 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 12 KRISTI NOEL O'BRIEN, 13 Plaintiff, 14 v. 15 16 ANDREW SAUL, Commissioner of Social Security, Defendant. 17 18 19 20 21 22 23 24 25 26 ) ) Case No.: 2:20-cv-01673-BNW ) ) UNOPPOSED MOTION FOR ) EXTENSION OF TIME ) (FIRST REQUEST) ) ) ) ) ) ) Defendant Andrew Saul, Commissioner of Social Security (Defendant) respectfully requests that the Court extend the time for Defendant to respond to Plaintiff’s Motion for Reversal and/or Remand (Dkt. No. 20, filed on May 17, 2021), currently due on June 16, 2021, by 30 days, through and including July 16, 2021. 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. Since Plaintiff’s motion was filed on May 17, 2021, Defendant’s counsel has worked on over 8 district court cases and filed two Ninth Circuit Case 2:20-cv-01673-BNW Document 21 Filed 06/01/21 Page 2 of 3 1 answering briefs. Counsel is also responsible for other substantive non-litigation matters in the Office 2 of General Counsel. The Office of General Counsel also currently has a number of attorneys out on 3 extended leaves of absence, in addition to staff attrition, which has increased the undersigned’s 4 workload. 5 Additional time is required to review the record, to evaluate the numerous issues raised in 6 Plaintiff’s motion, to determine whether options exist for settlement, and if not, to prepare Defendant’s 7 response to Plaintiff’s motion. Defendant’s counsel will endeavor to complete these tasks as soon as 8 possible. This request is made in good faith and with no intention to unduly delay the proceedings, 9 and counsel apologizes for any inconvenience. 10 On June 1, 2021, counsel for Defendant conferred with Plaintiff’s counsel, who has no 11 opposition to this motion. 12 It is therefore respectfully requested that Defendant be granted an extension of time to respond 13 to Plaintiff’s Motion for Reversal and Remand, through and including July 16, 2021. 14 15 Dated: June 1, 2021 Respectfully submitted, 16 CHRISTOPHER CHIOU Acting United States Attorney 17 /s/ Margaret Lehrkind MARGARET LEHRKIND Special Assistant United States Attorney 18 19 20 21 22 IT IS SO ORDERED: 23 UNITED STATES MAGISTRATE JUDGE 24 June 4, 2021 DATED: ___________________________ 25 26 2

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