Figueroa v. Commissioner of Social Security

Filing 20

ORDER granting 19 Letter Motion for Extension of Time to File. Application GRANTED. No further extensions of plaintiff's motion deadline will be granted. SO ORDERED. (Signed by Magistrate Judge Barbara C. Moses on 7/16/2021) (cf)

July 15, 2021
Document Electronically Filed
Hon. Barbara C. Moses
United States Magistrate Judge
U.S. District Court for the Southern District of New York
Daniel Patrick Moynihan United States Courthouse
500 Pearl Street
New York, NY 10007
Re:

7/16/21

Figueroa v. Commissioner of Social Security
Civil Action No: 1:20-cv-07649-BCM

Dear Judge Moses:
This letter respectfully requests an extension of time of forty-eight (48) days for Plaintiff
to serve her Motion for Judgment on the Pleadings in this matter. Plaintiff’s Motion for
Judgment on the Pleadings is currently due on July 21, 2021. Due to the unexpected loss of two
briefing attorneys last week, our office is unable to complete a proper, meritorious brief by the
current due date. This extension is needed to thoroughly and properly prepare Plaintiff’s Motion.
Plaintiff’s counsel has contacted defense counsel who consents to this request. This
request would be Plaintiff’s second extension in this matter.
If this request is granted, Plaintiff’s Motion for Judgment on the Pleadings will be due on
September 7, 2021. Subsequently, in accordance with the pattern of the Scheduling Order, the
Commissioner’s response to the Motion for Judgement on the Pleadings would then be due
November 8, 2021. Plaintiff’s Reply would then be due December 10, 2021.
Thank you for your consideration.

Respectfully submitted,
/s/ Howard D. Olinsky
Howard D. Olinsky, Esq.
Bar Code H06529
Counsel for Plaintiff

CC [via ECF]: Joseph Pantoja (Counsel for Defendant)
Application GRANTED. No further extensions of plaintiff's motion deadline will
be granted. SO ORDERED.
___________________________
Honorable Barbara C. Moses
Dated: __________________
July 16, 2021
U.S. Magistrate Judge
New York, NY