1 Melissa Newel (#148563) NEWEL LAW 2 2625 Alcatraz Ave., Suite 132 Berkeley, CA 94705 3 (510) 316-3827 4 [email protected]

5 Attorney for Plaintiff JERRY ANDRADE 6

7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 JERRY ANDRADE, No. 1:25-CV-001184 (BAM) 12 Plaintiff,

13 v. STIPULATION FOR BRIEFING EXTENSION; [PROPOSED] ORDER 14 COMMISSIONER OF SOCIAL SECURITY, 15 Defendant. 16 17

18

19 20

21

22 On September 12, 2025, Plaintiff Jerry Andrade filed the instant civil action for judicial 23 review of the defendant Commissioner of Social Security’s decision denying his application for 24 Social Security disability insurance benefits under Title II of the Social Security Act. (ECF Doc. 25 1) The Defendant responded to Plaintiff’s Complaint on November 13, 2023. (ECF Doc. 10) 26 Pursuant to the Court’s Scheduling Order, Plaintiff’s motion for summary judgment is currently 27 due to be filed no later than December 15, 2025. (ECF Doc. 5 at p.2:17-18) 28 1 Plaintiff requests an extension of thirty (30) days to file his motion. Id. at p.3:17-18. This 2 is Plaintiff’s first request for an extension of time. Plaintiff’s counsel seeks the extension to 3 effectively advocate for Plaintiff as counsel did not represent Mr. Andrade at the administrative 4 level and the record contains nearly 1,000 pages of medical evidence. See, Costa v. Comm’r of 5 Soc. Sec. Admin.,

, 1134 n. 1 (9th Cir. 2012) [noting “social security disability cases 6 are often highly fact-intensive and require careful review of the administrative record, including 7 complex medical evidence.”]. Plaintiff’s counsel apologizes to the Court for any inconvenience. 8 The defendant has no objection to the requested extension.

9 Respectfully submitted, 10 Dated: December 10, 2025 NEWEL LAW 11 By: Melissa Newel 12 Melissa Newel Attorney for Plaintiff 13 JERRY ANDRADE

14

15 Dated: December 10, 2025 ERIC GRANT United States Attorney 16 MATTHEW W. PILE Associate General Counsel 17 Office of Program Litigation, Office 7

18 By: Oscar Gonzalez de Llano* 19 OSCAR GONZALEZ DE LLANO Special Assistant United States Attorney 20 Attorney for Defendant (*authorized by email dated 12/10/2025) 21

22 23 24 25 26 27 28 1 ORDER

2 Good cause having been shown, IT IS ORDERED that Plaintiff shall be granted an 3 extension of time of thirty (30) days to file his Opening Brief. The Opening Brief shall be filed on 4 or before January 14, 2026 and all deadlines are modified accordingly. 5

6 IT IS SO ORDERED. 7 Dated: December 11, 2025 /s/ Barbara A. McAuliffe _ 8 UNITED STATES MAGISTRATE JUDGE 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28