(SS) Scoggins v. Commissioner of Social Security

1 Melissa Newel (#148563) NEWEL LAW 2625 Alcatraz Ave., Suite 132 Berkeley, CA 94705 (510) 316-3827 [email protected] Attorney for Plaintiff DEROME SCOGGINS UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA DEROME SCOGGINS, No. 2:24-CV-00974-CKD Plaintiff, v. MOTION FOR 30-DAY BRIEFING 13 EXTENSION; ORDER COMMISSIONER OF SOCIAL SECURITY, 15 Defendant.

20 On April 1, 2024, Plaintiff Derome Scoggins filed the above-referenced action seeking judicial review of the defendant Commissioner of Social Security’s denial of his claim for Social Security disability benefits. (ECF Doc. 1) The defendant responded to Plaintiff’s Complaint on May 31, 2024. (ECF Doc. 10). Plaintiff’s motion for summary judgment is currently due to be filed no later than July 1, 2024. (ECF Doc. 5, p. 2:12-13) 25 Pursuant to the Court’s Scheduling Order, Plaintiff HEREBY MOVES for an extension of thirty (30) days to file his motion for summary judgment. (ECF Doc. 5, p. 2:24-25) This is Plaintiff’s first request for an extension of time. Plaintiff’s counsel seeks the extension due to | conflicting filing deadlines in other matters and to effectively advocate for Plaintiff as Plaintiffs || counsel was not involved at the administrative level and a close review of the administrative || record concerning Plaintiff's medical issues and vocational background is necessary and required.

4 || See, Costa v. Comm’r of Soc. Sec. Admin., 690 F.3d 1132, 1134 n. 1 (9 Cir. 2012) [noting || “social security disability cases are often highly fact-intensive and require careful review of the || administrative record, including complex medical evidence.”].

7 On June 26, 2024, counsel for the Defendant informed Plaintiffs counsel by email that | the Commissioner of Social Security has no objection to the requested extension and does not || oppose Plaintiffs motion.

11 Respectfully submitted, || Dated: June 26, 2024 NEWEL LAW 14 By: Melissa Newel Melissa Newel 15 Attorney for Plaintiff DEROME SCOGGINS ORDER Good cause having been shown, IT IS ORDERED that Plaintiff shall be granted an || extension of thirty (30) days to file his Opening Brief. The Opening Brief shall now be filed on or || before July 31, 2024, and all corresponding deadlines are modified accordingly.

24 | Dated: June 26, 2024 / a 4a 7 ye ls a 2 CAROLYN K. DELANEY 26 UNITED STATES MAGISTRATE JUDGE