Cruz v. O'Malley
Filing
22
MEMO ENDORSEMENT granting 20 Motion for Attorney Fees. ENDORSEMENT: Plaintiff's extension request is GRANTED. Plaintiff is directed to file a memorandum of law in support of the motion by January 21, 2025 if the parties are unable to reach an agreement. (Signed by Magistrate Judge Valerie Figueredo on 11/22/2024) (sgz)
CHRISTOPHER JAMES BOWES, ESQ
54 Cobblestone Drive
Shoreham, New York 11786
Tel.: (212) 979-7575
Fax: (631) 929-1700
CJB-8865
Attorney for Plaintiff
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
-----------------------------------------X
FIORDLAIZA CRUZ,
:
Plaintiff,
:
NOTICE OF
FOR ATTORNEYS FEES
PURSUANT TO
28 U.S.C. § 2412
:
-against-
1:24 Civ. 823 (JPO)(VF)
:
MARTIN J. O’MALLEY,
COMMISSIONER OF SOCIAL SECURITY,
:
:
Defendant.
-----------------------------------------X
PLEASE TAKE NOTICE that upon the accompanying Declaration
of Christopher James Bowes, dated October 23, 2024, plaintiff
will move this Court before Honorable J. Paul Oetken, United
States District Judge presiding, at the United States
Courthouse, Southern District of New York, 500 Pearl Street, New
York, new York 10007, on submission, for an order, on
submission, for an order:
(1)
Accepting plaintiff's application for reasonable
attorney’s fees and costs pursuant to the Equal Access to
Justice Act ("EAJA"), 28 U.S.C. §2412(d), as timely filed; and
(2)
Granting plaintiff leave to defer filing a memorandum
of law in support of her application for fees for a period of 60
days to permit the parties an opportunity to reach settlement of
the fee issue; and
(3)
for such other and further relief as this Court may
deem just and proper.
Dated:
Shoreham, New York
November 21, 2024
Respectfully submitted,
/s/Christopher James Bowes
CHRISTOPHER JAMES BOWES, ESQ.
54 Cobblestone Drive
Plaintiff's extension request is GRANTED. Plaintiff Shoreham, New York 11786
is directed to file a memorandum of law in support Tel.: (212) 979-7575
of the motion by January 21, 2025 if the parties
Fax: (631) 979-1700
are unable to reach an agreement.
CJB-8865
Attorney for Plaintiff
Dated: 11/22/24
To:
Jonathan King, Esq.
Special Assistant United States Attorney
6401 Security Boulevard
Baltimore, MD 21235
Attorneys for Defendant
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