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 STACY D. DAVIDSON 6

7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 STACY D. DAVIDSON No. 1:25-CV-00766 (GSA) 12 Plaintiff,

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

18

19 20 On June 23, 2025, Plaintiff Stacy D. Davidson filed the instant civil action for judicial 21 review of the defendant Commissioner of Social Security’s decision denying her application for 22 Social Security disability benefits under Title II and XVI of the Social Security Act. (ECF Doc. 1) 23 On October 24, 2025, the Defendant requested, and was granted, an extension of time to respond 24 to Plaintiff’s Complaint. (ECF Doc. 10 and 11) On November 20, 2025, the Defendant lodged a 25 certified copy of the administrative record. (ECF Doc. 12) Pursuant to the Court’s Scheduling 26 Order, Plaintiff’s motion for summary judgment is currently due to be filed no later than 27 December 22, 2025. (ECF Doc. 9 at p.2:19-20) 28 1 Plaintiff requests an extension of sixty (60) days to file her motion. Id. at p.3:20-21. 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 Ms. Davidson at the administrative 4 level and the record contains 5,213 pages, including over 4,200 pages of medical evidence. See, 5 Costa v. Comm’r of Soc. Sec. Admin.,

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

9 Respectfully submitted, 10 Dated: December 16, 2025 NEWEL LAW 11 By: Melissa Newel 12 Melissa Newel Attorney for Plaintiff 13 STACY D. DAVIDSON

14

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

18 By: Christopher Vieira* 19 CHRISTOPER VIEIRA Special Assistant United States Attorney 20 Attorney for Defendant (*authorized by email dated 12/16/2025) 21

22 ORDER

23 Good cause having been shown, IT IS ORDERED that Plaintiff shall be granted an 24 extension of time of sixty (60) days to file her Opening Brief. The Opening Brief shall be filed on 25 or before February 20, 2026 and all deadlines are modified accordingly. 26

27 IT IS SO ORDERED. 28 1 Dated: December 17, 2025 /s/ Gary S. Austin 2 UNITED STATES MAGISTRATE JUDGE 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28