Staton v. Social Security
Filing
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ORDER Granting 13 Motion to Extend Time to File Certified Administrative Record and Answer. Commissioner Of Social Security answer due 11/25/2022. Signed by Magistrate Judge Daniel J. Albregts on 9/16/2022. (Copies have been distributed pursuant to the NEF - LOE)
Case 2:22-cv-01139-DJA Document 15 Filed 09/16/22 Page 1 of 4
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JASON M. FRIERSON
United States Attorney
Nevada Bar No. 7709
MICHONNE L. OMO, SB IL 6309833
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: (510) 970-4845
Facsimile: (415) 744-0134
E-Mail: michonne.omo@ssa.gov
Attorneys for Defendant
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
DYLAN STATON,
Plaintiff,
vs.
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KILILO KIJAKAZI,
Acting Commissioner of Social Security,
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Defendant.
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Case No.: 2:22-cv-01139-DJA
UNOPPOSED MOTION FOR EXTENSION OF
TIME TO FILE CERTIFIED
ADMINISTRATIVE RECORD AND ANSWER
(FIRST REQUEST)
Case 2:22-cv-01139-DJA Document 15 Filed 09/16/22 Page 2 of 4
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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 60-day extension of time to file the Certified
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Administrative Record (CAR) and answer to Plaintiff’s Complaint. The CAR and answer to Plaintiff’s
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Complaint are due to be filed by September 26, 2022. This is the Commissioner’s first request for an
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extension of time.
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Defendant submits that good cause exists for this extension request. There was a mix-up when
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the Office of the General Counsel was notified of this case, and the Office of Appellate Operations
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(which prepares and certifies the certified administrative record) did not receive notice of this case until
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recently. The undersigned apologizes for this delay. OAO has requested the undersigned seek 60 days
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for them to prepare the CAR.
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Accordingly, Defendant requests an extension in which to respond to the Complaint until
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November 25, 2022. If Defendant is unable to produce the certified administrative record necessary to
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file an Answer in accordance with this Order, Defendant shall request an additional extension prior to the
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due date.
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The undersigned conferred with Plaintiff’s counsel, who confirmed on September 15, 2022, that
Plaintiff 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 the CAR
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and answer to Plaintiff’s Complaint, through and including November 25, 2022.
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Unopposed Mot. for Ext.; No. 2:22-cv-01139-DJA
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Case 2:22-cv-01139-DJA Document 15 Filed 09/16/22 Page 3 of 4
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Dated: September 15, 2022
JASON M. FRIERSON
United States Attorney
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/s/ Michonne L. Omo
MICHONNE L. OMO
Special Assistant United States Attorney
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IT IS SO ORDERED:
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DANIEL J.
ALBREGTS
UNITED
STATES
MAGISTRATE JUDGE
UNITED STATES MAGISTRATE JUDGE
DATED: ___________________________
DATED: September 16, 2022
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Unopposed Mot. for Ext.; No. 2:22-cv-01139-DJA
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Case 2:22-cv-01139-DJA Document 15 Filed 09/16/22 Page 4 of 4
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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 CERTIFIED ADMINISTRATIVE RECORD AND ANSWER
on the following parties by electronically filing the foregoing with the Clerk of the District Court using
its ECF System, which provides electronic notice of the filing:
Hal Taylor
haltaylorlawyer@gbis.com
I declare under penalty of perjury that the foregoing is true and correct.
Dated: September 15, 2022
/s/ Michonne L. Omo
MICHONNE L. OMO
Special Assistant United States Attorney
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Unopposed Mot. for Ext.; No. 2:22-cv-01139-DJA
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