Opinion
2:22-cv-01871-EJY
04-24-2023
DAMON WALKER, JR., Plaintiff, v. KILOLO KIJAKAZI, ACTING COMMISSIONER OF SOCIAL SECURITY, Defendant.
Hal Taylor, Esq. Of Counsel, Olinsky Law Group NV Bar No.: 4399 Attorney for Plaintiff
Hal Taylor, Esq. Of Counsel, Olinsky Law Group NV Bar No.: 4399 Attorney for Plaintiff
CONSENT MOTION FOR EXTENSION OF TIME TO FILE PLAINTIFF'S BRIEF
Plaintiff by his 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 April 28, 2023.
Counsel requires additional time to properly and thoroughly prepare Plaintiff's brief. For instance, between April 21, and May 22, 2023, staff in Counsel's office have one hundred and five (105) 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 opening brief by the current deadline. This request will not cause Defendant any undue hardship.
Wherefore, Plaintiff requests an extension from April 28, 2023 up to and including June 27, 2023 to file their brief. Counsel for the Plaintiff has conferred with Defendant's Counsel who consents to this request.
Plaintiff's Certificate of Service:
I certify that I caused the Consent Motion for Extension of Time to be served today, April 21, 2023, by CMECF to Edmund (Jack) Darcher, and Blaine T Welsh, who are filing users of the CM/ECF system.
IT IS SO ORDERED.