Carhart v. Commissioner of Social Security

Filing 12

ORDER granting 11 Letter Motion for Extension of Time to File. Application GRANTED. No further extensions absent good cause shown. SO ORDERED.. (Signed by Magistrate Judge Robyn F. Tarnofsky on 7/3/2024) (jca)

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Document Electronically Filed Hon. Robyn F. Tarnofsky United States Magistrate Judge United States District Court for the Southern District of New York Daniel Patrick Moynihan U.S. Courthouse 500 Pearl Street New York, NY 10007-1312 Re: July 1, 2024 Carhart v. O’Malley, Commissioner of Social Security Docket No: 1:24-cv-02634-JGLC-RFT Hon. Judge Tarnofsky: This letter respectfully requests an extension of time of twenty-eight (28) days for Plaintiff to file Plaintiff’s Brief in this matter, to August 7, 2024. Plaintiff’s Brief is currently due on July 10, 2024; however, Plaintiff cannot complete the Brief on time for the reasons detailed below. Counsel requests this extension due to multiple, simultaneous filing deadlines. Counsel requires additional time to prepare Plaintiff’s brief properly and thoroughly. For instance, between June 28, and August 5, 2024, staff in Counsel’s office have ninety-five (95) Plaintiff briefs due. This figure does not include briefings which will be due after the filing of Administrative Records throughout this timeframe, Oral Arguments, appeals to Circuit Courts, Reply Briefs, settlement negotiations, and the various other tasks which arise throughout the course of litigation. These circumstances do not allow for Plaintiff’s Counsel to properly prepare the brief by the current deadline. This request will not cause Defendant any undue hardship. This extension is needed to prepare the brief thoroughly and properly. Plaintiff’s counsel has contacted defense counsel who has no objection to this request and has agreed to the below briefing schedule. This request will not cause Defendant any undue hardship. The parties have agreed on the briefing schedule below. This would be a first request for an extension of time in this matter. If Plaintiff’s request is granted, the new briefing schedule would be: // // Plaintiff’s Brief is due on or before August 7, 2024; Defendant’s Brief is due on or before October 7, 2024; and Plaintiff’s Reply Brief, if any, is due on or before October 28, 2024. Thank you for your consideration. Respectfully submitted, /s/ Howard D. Olinsky Howard D. Olinsky, Esq. Counsel for Plaintiff CC [via ECF]: Ariella Renee Zoltan, Esq., Attorney for Defendant Application GRANTED. No further extensions absent good cause shown. DATED: July 3, 2024 New York, New York

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