Lieberman v. Berryhill

Filing 49

MEMO ENDORSED ORDER granting 45 Motion for Attorney Fees. ENDORSEMENT: Plaintiff's request is GRANTED. Plaintiff shall file her memorandum of law in support of her application for fees on or before May 26, 2024. The Commissioner shall file a response to Plaintiff's motion on or before June 17, 2024. The Clerk of the Court is directed to terminate the motion at ECF No. 45. SO ORDERED. (Signed by Judge Nelson Stephen Roman on 3/27/24) (yv)

CHRISTOPHER JAMES BOWES, ESQ
54 Cobblestone Drive
Shoreham, New York 11786
Tel.: [phone]
Fax: [phone]
CJB-8865
Attorney for Plaintiff

03/27/2024

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
-----------------------------------------X
LISA LIEBERMAN,
:
Plaintiff,

:

NOTICE OF
FOR ATTORNEYS FEES
PURSUANT TO
28 U.S.C. § 2412

:
-against-

7:19 Civ.2870 (NSR)(AEK)
:

MARTIN J. O’MALLEY,
COMMISSIONER OF SOCIAL SECURITY,

:
:

Defendant.
-----------------------------------------X
PLEASE TAKE NOTICE that upon the accompanying Declaration
of Christopher James Bowes, dated March 23, 2024, plaintiff will
move this Court before Honorable Nelson S. Roman, United States
District Court Judge presiding, at the United States Courthouse,
Southern District of New York, 300 Quarropas Street, White
Plains, New York, 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
March 23, 2024

Respectfully submitted,
/s/Christopher James Bowes
CHRISTOPHER JAMES BOWES, ESQ.
54 Cobblestone Drive
Shoreham, New York 11786
Tel.: [phone]
Fax: [phone]
CJB-8865
Attorney for Plaintiff

To:

Elizabeth Kim, Esq.
Assistance United States Attorney
86 Chambers Street, 3rd Floor
New York, NY 10007
Attorneys for Defendant

Plaintiff's request is GRANTED. Plaintiff shall file her memorandum of law in support of her
application for fees on or before May 26, 2024. The Commissioner shall file a response to
Plaintiff's motion on or before June 17, 2024. The Clerk of the Court is directed to terminate the
motion at ECF No. 45.
Dated: March 27, 2024
White Plains, NY