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)

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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: (212) 264-2303 Office of the General Counsel fax: (212) 264-6372 26 Federal Plaza, Room 3904 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: 212.264.2303 Fax: 212.264.6372 E-mail: cc: Christopher Bowes, Esq. Via CM/ECF Granted. No further extensions. 5/9/2022

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