Filed: Jun. 13, 2018
Latest Update: Jun. 13, 2018
Summary: UNOPPOSED MOTION TO EXTEND TIME TO FILE MOTION FOR REVERSAL AND/OR REMAND (FIRST REQUEST) PEGGY A. LEEN , Magistrate Judge . Plaintiff Naim R. Costandi respectfully requests that the Court extend the time for Plaintiff to file her Motion for Reversal and/or Remand by 35 days from June 7, 2018 to July 12, 2018, with all other dates in the Court's Order Concerning Review Of Social Security Cases extended accordingly. Of Counsel for Plaintiff has conferred with Defendant's counsel, who has no
Summary: UNOPPOSED MOTION TO EXTEND TIME TO FILE MOTION FOR REVERSAL AND/OR REMAND (FIRST REQUEST) PEGGY A. LEEN , Magistrate Judge . Plaintiff Naim R. Costandi respectfully requests that the Court extend the time for Plaintiff to file her Motion for Reversal and/or Remand by 35 days from June 7, 2018 to July 12, 2018, with all other dates in the Court's Order Concerning Review Of Social Security Cases extended accordingly. Of Counsel for Plaintiff has conferred with Defendant's counsel, who has no ..
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UNOPPOSED MOTION TO EXTEND TIME TO FILE MOTION FOR REVERSAL AND/OR REMAND
(FIRST REQUEST)
PEGGY A. LEEN, Magistrate Judge.
Plaintiff Naim R. Costandi respectfully requests that the Court extend the time for Plaintiff to file her Motion for Reversal and/or Remand by 35 days from June 7, 2018 to July 12, 2018, with all other dates in the Court's Order Concerning Review Of Social Security Cases extended accordingly. Of Counsel for Plaintiff has conferred with Defendant's counsel, who has no opposition to this motion, on June 11, 2018.
This is Plaintiff's first request for an extension. As the Court may be aware of Plaintiff's Of Counsel situation with other Social Security cases, Counsel's mother has been fighting a losing battle with Systemic Lupus Erythematosus that has required multiple surgeries these past two years due inflammation affecting the kidneys and lungs. On February 6, 2018, Of Counsel's mother was taken to the emergency room and was admitted to the hospital. On February 8, 2018, Of Counsel's mother had a surgery to avoid further kidney obstruction due to the Lupus inflammation and kidney infection.
On February 16, 2018, Of Counsel's husband's mother suffered two ischemic strokes, requiring 24-hour daily care for her activities of daily living up to present day, which Of Counsel has had to assist with. On March 28, 2018, Of Counsel's mother was advised that another kidney surgery was medically necessary. On May 8, 2018, Of Counsel's mother had the first of three procedures to her kidney. On May 25, 2018, Of Counsel's mother was informed that the kidney infection is not curable, and the first of three kidney surgeries will take place July 17, 2018.
On June 7, 2018 at 3:30 a.m., Of Counsel's husband suffered a micturition syncope resulting in a concussion, 17 staples to his head, and a blood transfusion. Of Counsel was in the hospital with her husband on June 7, 2018 and required her attention for 24-hour watch due to the concussion.
This is not an ordinary circumstance for Of Counsel and Of Counsel sincerely apologizes to the Court for any inconvenience this may have cause.
IT IS SO ORDERED.
