Opinion
2:23-cv-00720-EJY
07-24-2023
IVAN EARL BARNES, Plaintiff, v. KILOLO KIJAKAZI, ACTING COMMISSIONER OF SOCIAL SECURITY, Defendant.
Hal Taylor, Esq. Of Counsel, Olinsky Law Group Attorney for Plaintiff
Hal Taylor, Esq. Of Counsel, Olinsky Law Group Attorney for Plaintiff
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE PLAINTIFF'S BRIEF
Plaintiff, Ivan Earl Barnes, by his attorney, moves for a sixty (60) day extension of time to file Plaintiff s opening brief. Plaintiffs opening brief is currently due to be filed July 31, 2023.
Counsel requests this extension due to multiple, simultaneous filing deadlines. Counsel requires additional time to properly and thoroughly prepare Plaintiffs brief. For instance, between July 28, and September 22, 2023, staff in Counsel's office have two hundred and eleven (211) Plaintiff briefs due. This figure does not include 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 Plaintiffs Counsel to properly prepare the brief by the current deadline. This request will not cause Defendant any undue hardship. This extension is needed to thoroughly and properly prepare the brief.
Wherefore, Plaintiff requests an extension from July 31, 2023, up to and including September 29, 2023 to file their brief. Counsel for the Plaintiff has conferred with Defendant's Counsel who kindly has no objection to this request.
IT IS SO ORDERED