Opinion
2:23-cv-00891-RFB-VCF
10-12-2023
JULIE LYNN FRY, 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
CAM FERENBACH UNITED STATES MAGISTRATE JUDGE
Plaintiff, Julie Lynn Fry, by her attorney, moves for a sixty (60) day extension of time to file Plaintiff's opening brief. Plaintiff's opening brief is currently due to be filed October 16, 2023.
Counsel requests this extension due to multiple, simultaneous filing deadlines. Counsel requires additional time to properly and thoroughly prepare Plaintiff's brief. For instance, between October 6, and December 8, 2023, staff in Counsel's office have one hundred and ninety (190) 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 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 thoroughly and properly prepare the brief.
Wherefore, Plaintiff requests an extension from October 16, 2023, up to and including December 15, 2023 to file her brief. Counsel for the Plaintiff has conferred with Defendant's Counsel who kindly has no objection to this request.
Dated October 10, 2023.
Hal Taylor, Esq.
Plaintiff's Certificate of Service:
I certify that I caused the Unopposed Motion for Extension of Time to be served today, October 10, 2023, by CMECF to Blaine T. Welsh, Esq., and Franco Becia, Esq., who are filing users of the CM/ECF system.
Hal Taylor
IT ISSOORDERED.