Arias v. Saul

Filing 25

ORDER granting 24 Letter Motion for Extension of Time to File. Granted. No further extensions. SO ORDERED. (Signed by Magistrate Judge Robert W. Lehrburger on 5/9/2022) (vfr)

Case 1:21-cv-03118-RWL Document 25 Filed 05/09/22 Page 1 of 2
U.S. Department of Justice
United States Attorney
Southern District of New York
Civil Division
c/o Social Security Administration tel: [phone]
Office of the General Counsel
fax: [phone]
26 Federal Plaza, Room 3904
[e-mail]
New York, New York 10278

May 9, 2022

BY CM/ECF
Honorable Robert W. Lehrburger
United States Magistrate Judge
United States Courthouse
500 Pearl Street
New York, New York 10007-1312
Re:

5/9/2022

Arias v. Comm’r of Soc. Sec.
1:21-cv-03118-RWL

Dear Judge Lehrburger:
This Office represents Defendant in the above-referenced action. We write respectfully to
request an additional second 30-day extension of time for Defendant to file her Cross-Motion for
Judgment on the Pleadings and Response to Plaintiff’s Motion for Judgment on the Pleadings,
currently due on May 18, 2022, to June 17, 2022. The reason for the request is that the Regional
Counsel’s Office is currently experiencing very heavy workload constraints, and more time is
needed to review the record and prepare the Commissioner’s response. In addition, the Arias
record is over 3,000 pages and the case contains complex issues. This 30-day extension of time
will allow the undersigned to have sufficient time to review the record and respond to Plaintiff’s
motion. This is Defendant’s second request for an extension of time to file her cross-motion in
this case, and we apologize for any inconvenience to the Court. Plaintiff’s counsel, Christopher
Bowes, has graciously consented to the Defendant’s extension request.
In the event that this motion is granted, Plaintiff’s reply brief, which was originally due on May
27, 2022, will be due on June 27, 2022.
We thank this Court for its time and consideration.

Respectfully,
DAMIAN WILLIAMS
United States Attorney

Case 1:21-cv-03118-RWL Document 25 Filed 05/09/22 Page 2 of 2

By:

s/Maria Fragassi Santangelo
MARIA FRAGASSI SANTANGELO
Special Assistant United States Attorney
c/o Social Security Administration
26 Federal Plaza, Room 3904
New York, New York 10278
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]

cc: Christopher Bowes, Esq.
Via CM/ECF

Granted. No further extensions.
5/9/2022