Perez v. Kijakazi

• Court: District Court, S.D. New York
• Decided: March 22, 2022
• Docket: 1:21-cv-07902
• Status: Unknown

Opinion

id | yealth eee => . ELECTRONICALLY FILED e555 = | Provect DOC #: alia amen oe E> DATE FILED:__ 03/22/2022

21 March 2022

Honorable Stewart D. Aaron Sheena cee Vork Request GRANTED. SO ORDERED. outhern District of New Yor Dated: March 22, 2022 Daniel Patrick Moynahan Aor cf Chon. United States Courthouse 500 Pearl Street New York, NY 10007-1312 Re: Perez v. Kijakazi, 21 CV 07902 (SDA) Dear Judge Aaron: | represent the Plaintiff, Krystalie Perez, in this Social Security appeal of a dismissal of her case. | write now to respectfully request an extension of time to file Plaintiff's motion for judgment on the pleadings and to modify the breifing schedule. This is Plaintiff's first request for an extension of time, and it would be the first extension of time for any deadlines. This request is not made on consent because Defendant’s counsel has not replied to my inquiries. Since last Monday, | emailed twice and called and left voicemail messages twice for Ms. Treanor, the most recent counsel for Defendant to appear. The email address for Mr. Kershner no longer works, but his telephone number provides an alternative number to call. | called that new number and left a message, but | did not hear back. Previously in this case, the Commissioner filed the certified administrative transcript on January 24, 2022 (Dkt. 12). The current scheduling order, based on the standing order for scheduling, requires Plaintiff to file her motion within 60 days, or on or by Friday, March 24, 2022 (Dkt. 5). Plaintiff now requests a four-week extension of time to file her motion and papers. Plaintiff makes this request because this small practice in my office has been short-staffed for several months and | am also assisting in the supervision of new hires. An extension of time would allow me to better manage the demands of the next few weeks. Also, | am unexpectedly out of the office for several days this week for personal reasons. Therefore, | respectfully request an extension of time for the filing of Plaintiff’s motion and brief to Friday, April 22, 2022. Under current Standing Order 16 Misc. 171, the briefing schedule would change to the following dates:

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Plaintiff’s brief: April 22, 2022 Defendant’s Cross Motion: June 21, 2022 Plaintiff’s reply : July 12, 2022 Thank you for considering this request. Sincerely,

/s/ Ann P. Biddle Litigation Supervisor Mental Health Project cc: Victoria Treanor Special Assistant U.S. Attorney c/o Social Security Administration 26 Federal Plaza, Room 3904 New York, NY 10278 (212)264-2524 Victoria.treanor@ssa.gov Filed via ECF