Villegas v. Commissioner of the Social Security Administration

Filing 14

MEMO ENDORSED ORDER granting 13 Motion for Extension of Time to File. ENDORSEMENT: Application Granted. The Clerk of Court is directed to terminate the motion at ECF No. 13. (Signed by Magistrate Judge Valerie Figueredo on 11/13/2023) (vfr)

Case 1:23-cv-07026-VF Document 13 Filed 11/10/23 Page 1 of 2

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
---------------------------------------------------------x
CAROL VILLEGAS,

Case No.: 1:23-cv-7026-VF

Plaintiff,
vs.
COMMISSIONER OF THE
SOCIAL SECURITY ADMINISTRATION,
Defendant.
----------------------------------------------------------x

November 13, 2023

The Clerk of Court is directed to
terminate the motion at ECF No. 13.

MOTION FOR AN EXTENSION OF TIME
TO FILE THE PLAINTIFF’S BRIEF / MOTION
Plaintiff, by and through her attorney of record, BRYAN KONOSKI, hereby moves for an
extension of time to file the Plaintiff’s Brief/Motion, and shows unto the Court as follows:
1. I am a Partner with Konoski & Partners, P.C.
2. I am the Plaintiff’s attorney.
3. The Plaintiff’s brief is due November 10, 2023.
4. I am requesting that the Court grant a thirty (30) day extension of time to file the Plaintiff’s
brief. This is the Plaintiff’s first request for an extension of time.
5. The reason for the extension request is that, while substantial progress was made on this
brief, I had multiple briefs due last month and was unable to complete this brief in a timely
manner.
6. Due to the Veterans Day federal holiday, I have been unable to speak with defense counsel
to ask for their consent.
7. For these reasons, I kindly ask that the Court grant an extension of time to December 10,
2023, to file the Plaintiff’s brief.

Case 1:23-cv-07026-VF Document 13 Filed 11/10/23 Page 2 of 2

Dated: November 10, 2023
Respectfully submitted,
s/ Bryan Konoski
By: Bryan Konoski, Esq.
Attorney(s) for the Plaintiff
Konoski & Partners, P.C.
305 Broadway, 7th Floor
New York, NY 10007
[phone]
Fax: [phone]
[e-mail]

Case 1:23-cv-07026-VF Document 13-1 Filed 11/10/23 Page 1 of 1

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
---------------------------------------------------------x
CAROL VILLEGAS,

Case No.: 1:23-cv-7026-VF

Plaintiff,
vs.
COMMISSIONER OF THE
SOCIAL SECURITY ADMINISTRATION,
Defendant.
----------------------------------------------------------x
ORDER
WHEREAS the Plaintiff filed a motion requesting that the Court grant a thirty (30) day
extension of time to file the Plaintiff’s Brief; It is hereby
ORDERED that the Plaintiff’s motion is granted and the Plaintiff is directed to file
Plaintiff’s Brief by December 10, 2023.

SO ORDERED
____________________________

Case 1:23-cv-07026-VF Document 13-2 Filed 11/10/23 Page 1 of 1

DECLARATION OF SERVICE

I, the undersigned, being sworn, say: I am not a party to the action, am over 18 years of
age, and practice law with offices located in New York, NY. On the 10 th day of November 2023, I
served the within MOTION FOR AN EXTENSION OF TIME TO FILE THE PLAINTIFF’S
BRIEF/MOTION by: electronically filing said documents with the Clerk of the Court through
the ECF system, which was then electronically served upon the Defendant through Defendant’s
Counsel.
I declare under penalty of perjury that the foregoing is true and correct.
Dated: November 10, 2023
Respectfully submitted,
s/ Bryan Konoski
By: Bryan Konoski, Esq.
Attorney(s) for the Plaintiff
Konoski & Partners, P.C.
305 Broadway, 7th Floor
New York, NY 10007
[phone]
Fax: [phone]
[e-mail]