Carr v. Kijakazi

Filing 29

ORDER Granting 28 Motion to Extend Time. Cross-Motion to Affirm and Responses re 27 Motion to Remand to Agency due by 1/23/2023. Signed by Magistrate Judge Daniel J. Albregts on 1/17/2023. (Copies have been distributed pursuant to the NEF - TRW)

Case 2:22-cv-01069-DJA Document 29
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JASON M. FRIERSON
United States Attorney
Nevada Bar No. 7709
ANDREA BANKS, CSBN 275286
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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TORRANCE CARR,

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Plaintiff,
vs.
KILILO KIJAKAZI,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 2:22-cv-01069-DJA
UNOPPOSED MOTION FOR EXTENSION OF
TIME TO FILE DEFENDANT’S CROSSMOTION TO AFFIRM AND RESPONSE TO
PLAINTIFF’S MOTION FOR REVERSAL
(FIRST REQUEST)

Case 2:22-cv-01069-DJA Document 29
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Defendant, Kilolo Kijakazi, Acting Commissioner of Social Security (the “Commissioner”), by

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and through her undersigned attorneys, hereby moves for a 10-day extension of time to file Defendant’s

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Cross-Motion to Affirm and Response to Plaintiff’s Motion for Reversal. The current deadline is January

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13, 2023. This is the Commissioner’s first request for an extension of time.

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Defendant submits that good cause exists for this extension request. Defendant’s counsel is

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conferring with her client regarding the issues raised in this case and possible settlement. Defendant

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respectfully requests a 10 day extension to allow time for a response from her client.

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On January 12, 2023, the undersigned conferred with Plaintiff’s counsel, who has no opposition to
the requested extension.

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It is therefore respectfully requested that Defendant be granted an extension of time to file Cross-

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Motion to Affirm and Response to Plaintiff’s Motion for Reversal, through and including Monday, January

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23, 2023.

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Dated: January 12, 2023

JASON M. FRIERSON
United States Attorney

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/s/ Andrea Banks
ANDREA BANKS
Special Assistant United States Attorney
Attorneys for Defendant

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IT IS SO ORDERED:

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UNITED STATES MAGISTRATE JUDGE

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January 17, 2023
DATED: ___________________________

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Unopposed Mot. for Ext.; No. 2:22-cv-01069-DJA

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Case 2:22-cv-01069-DJA Document 29
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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 DEFENDANT’S CROSS-MOTION TO AFFIRM AND
RESPONSE TO PLAINTIFF’S MOTION FOR REVERSALon the following parties by

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electronically filing the foregoing with the Clerk of the District Court using its ECF System, which

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provides electronic notice of the filing:

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Leonard Stone
Shook & Stone, Chtd.
710 S Fourth Street
Las Vegas, NV 89101
702-385-2220
Email: [e-mail]
Marc V Kalagian
Law Offices of Lawrence D. Rohlfing, Inc., CPC
12631 East Imperial Highway,
Suite C115
Santa Fe Springs, CA 90670
[phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Plaintiff
I declare under penalty of perjury that the foregoing is true and correct.
Dated: January 12, 2023
/s/ Andrea Banks
ANDREA BANKS
Special Assistant United States Attorney

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Unopposed Mot. for Ext.; No. 2:22-cv-01069-DJA