Garcia v. Commissioner of Social Security

Filing 25

ORDER: granting 24 Letter Motion for Extension of Time to File. The proposed scheduled is approved. SO ORDERED. (Signed by Magistrate Judge Gabriel W. Gorenstein on 2/17/2021) (ama)

Case 1:20-cv-05066-JPC-GWG Document 24 Filed 02/16/21 Page 1 of 2
25
02/17/21

O S B O R N L A W, p.c.
43 West 43rd Street, Suite131
New York, New York 10036
DANIEL A. OSBORN
LINDSAY M. TRUST

TELEPHONE
212 - 725 - 9800
FACSIMILE
212 - 500 - 5115

February 16, 2021

MEMORANDUM ENDORSEMENT

VIA ECF
Honorable Gabriel W. Gorenstein
United States Magistrate Judge
United States District Court
Southern District of New York
Daniel Patrick Moynihan
United States Courthouse
500 Pearl Street
New York, New York 10007-1312
Re:

Garcia v. Commissioner of Social Security,
Civil Action No. 1:20-cv-05066-JPC-GWG

Dear Judge Gorenstein,
We write on behalf of plaintiff, Maricela Garcia, and with
the consent of the defendant, to request a 14-day extension of time
to file plaintiff’s motion for judgment on the pleadings. Plaintiff’s
motion is due on February 18, 2021. Plaintiff respectfully requests
an extension of time up to and including March 4, 2021. This is
plaintiff’s first request for an extension of time and it is
respectfully requested so that the parties can engage in discussions
regarding a voluntary remand of this case.

25
02/17/21
Case 1:20-cv-05066-JPC-GWG Document 24 Filed 02/16/21 Page 2 of 2

Honorable Gabriel W. Gorenstein
February 16, 2021
Page 2
Subject to the approval of the Court, the parties propose the
following revised briefing schedule:
a. Plaintiff to serve his motion for judgment on the
pleadings on or before March 4, 2021;
b. Defendant to serve its response/cross-motion on or
before May 3, 2021; and
c. Plaintiff to serve his reply (if any) on or before May
24, 2021.
Thank you for your consideration of this request.

Respectfully submitted,
s/Daniel A. Osborn
Daniel A. Osborn
OSBORN LAW, P.C.
43 West 43rd Street, Suite 131
New York, New York 10036
Telephone:
212-725-9800
Facsimile:
212-500-5115
[e-mail]

cc: Joseph Pantoja, Esq. (by ECF)

The proposed schedule is approved.
So Ordered.

February 17, 2021