1 Melissa Newel (#148563)

NEWEL LAW

2 2625 Alcatraz Ave., Suite 132 Berkeley, CA 94705 3 (510) 316-3827 4 mnewel@newellawfirm.com

5 Attorney for Plaintiff

CRYSTAL JOY CHITTY

6

7

UNITED STATES DISTRICT COURT

8

EASTERN DISTRICT OF CALIFORNIA

9 10 CRYSTAL JOY CHITTY, No. 2:24-CV-01945 (CKD) 11 Plaintiff, 12 v. MOTION FOR 30-DAY BRIEFING 13 EXTENSION; ORDER

COMMISSIONER OF

14 SOCIAL SECURITY, 15 Defendant. 16 17 On July 16, 2024, Plaintiff Crystal Joy Chitty filed the above-referenced action seeking 18 judicial review of the defendant Commissioner of Social Security’s denial of her claim for Social 19 Security disability benefits. (ECF Doc. 1) The defendant responded to Plaintiff’s Complaint on 20 September 20, 2024. (ECF Doc. 10). Pursuant to the Court’s Scheduling Order, Plaintiff’s motion 21 for summary judgment is due to be filed on or before October 21, 2024. (ECF Doc. 7, at p.2:12- 22 14) 23 Plaintiff HEREBY MOVES for an extension of thirty (30) days within which to file her 24 motion for summary judgment. (ECF Doc. 7, at p.2:24-25) This is Plaintiff’s first request for an 25 extension of time. Counsel seeks the extension due to conflicting briefing deadlines in other 26 matters and, as Plaintiff’s counsel was not involved at the administrative level, to effectively 27 advocate for Plaintiff as a close review of the administrative record concerning Plaintiff’s medical 28 ] || issues is necessary and required. See, Costa v. Comm’r of Soc. Sec. Admin., 690 F.3d 1132, 1134 2 | n. 1 9" Cir. 2012) [noting “social security disability cases are often highly fact-intensive and 3 || require careful review of the administrative record, including complex medical evidence.”]. 4 On October 11, 2024, counsel for the Defendant informed Plaintiff's counsel by email that 5 || the Commissioner of Social Security has no objection to the requested extension and does not 6 || oppose Plaintiffs motion. 7 8 Respectfully submitted, 9 | Dated: October 11, 2024 NEWEL LAW 10 By: Melissa Newel Melissa Newel 12 Attorney for Plaintiff 3 CRYSTAL JOY CHITTY

14 15 16 ORDER 17 Good cause having been shown, IT IS ORDERED that Plaintiff's motion for extension of 18 time (ECF NO. 11) is GRANTED. Plaintiff?s Opening Brief shall now be filed on or before ” November 20, 2024, and all corresponding deadlines are modified accordingly. 20 91 | Dated: October 16, 2024 Card i. L-Ao a

CAROLYN K. DELANEY

UNITED STATES MAGISTRATE JUDGE

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