(SS) Rangel v. Commissioner of Social Security

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STIPULATION AND UNOPPOSED MOTION FOR BRIEFING EXTENSION; ORDER
Melissa Newel (CA SB#148563)
NEWEL LAW
2625 Alcatraz Ave., Suite 132
Berkeley, CA 94705
(510) 316-3827
mnewel@newellawfirm.com
Attorney for Plaintiff
RAUL RANGEL
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
RAUL RANGEL,
Plaintiff,
v.
COMMISSIONER OF
SOCIAL SECURITY,
Defendant.
No. 1:26-cv-05567-SKO
STIPULATION AND UNOPPOSED
MOTION FOR BRIEFING EXTENSION;
ORDER
(Doc. 11)
On July 17, 2026, Plaintiff Raul Rangel filed a civil action for judicial review of the
defendant Commissioner of Social Security’s decision denying his application for Social Security
disability insurance benefits under Title II of the Social Security Act. (ECF Doc. 1) The Defendant
responded to Plaintiff’s Complaint on September 17, 2026. (ECF Doc. 10) Plaintiff’s motion for
summary judgment is due to be filed on or before October 19, 2026. (ECF Doc. 4, p.2:16-17)
Pursuant to this Court’s Scheduling Order, Plaintiff seeks an extension of thirty (30) days to
file his motion. (ECF Doc. 4 at p. 3:20-21) This is Plaintiff’s first request for an extension of time.
Plaintiff’s counsel seeks the extension due to unanticipated out-of-state travel and time away from
Case 1:26-cv-05567-SKO Document 12 Filed 10/14/26 Page 1 of 2

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STIPULATION AND UNOPPOSED MOTION FOR BRIEFING EXTENSION; ORDER
the office in connection with a family member’s terminal illness. Plaintiff’s counsel was not
involved at the administrative level of Mr. Rangel’s claim and the Certified Administrative Record
lodged with the Court by the Defendant totals almost 3,000 pages. (ECF Doc.10) “[S]ocial security
disability cases are often highly fact-intensive and require careful review of the administrative
record, including complex medical evidence.” Costa v. Comm’r. of Soc. Sec. Admin., 690 F.3d
1132, 1134 at n.1 (9th Cir. 2021). The Defendant has no objection to the requested extension.
Respectfully submitted,
Dated: October 13, 2026 NEWEL LAW
By: Melissa Newel
Melissa Newel
Attorney for Plaintiff
RAUL RANGEL
Dated: October 13, 2026 ERIC GRANT
United States Attorney
MATHEW W. PILE
Head of Program Litigation 1
Social Security Administration
By: Erin Jurrens*
ERIN JURRENS
Special Assistant United States Attorney
Attorney for Defendant
*(authorized by email dated 10/13/2026)
ORDER
Good cause having been shown (Fed. R. Civ. P. 16(b)(4)), IT IS ORDERED that Plaintiff
shall be granted an extension of time of thirty (30) days to file his Opening Brief. The Opening
Brief shall be filed on or before November 18, 2026, and all deadlines set forth in the Scheduling
Order (Doc. 4) are modified accordingly.
IT IS SO ORDERED.
Dated: October 14, 2026 /s/ Sheila K. Oberto .
UNITED STATES MAGISTRATE JUDGE
Case 1:26-cv-05567-SKO Document 12 Filed 10/14/26 Page 2 of 2