JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME FOR DEFENDANT TO RESPOND TO PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT

EDMUND F. BRENNAN, Magistrate Judge.

IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that the time for responding to Plaintiff's Motion for Summary Judgment be extended for thirty days from November 17, 2017 to December 17, 2017. This is Defendant's first request for extension. Good cause exists to grant Defendant's request for extension. Counsel for Defendant (Counsel) was on intermittent medical leave due to a recent hand injury and for chronic migraines. As a result of Counsel's unanticipated medical leave, Counsel became behind on her caseload. Counsel currently has an active caseload of over 70 pending active social security matters that require two or more dispositive motions a week until mid-December. In addition, Counsel has a Ninth Circuit brief due on or around December 12, 2017. Due to shortened staff and high workload demands, Defendant respectfully requests additional time in order to adequately assess the issues raised in Plaintiff's Motion. Counsel apologizes for the belated nature of the request, but did not anticipate taking additional medical leave. Defendant makes this request in good faith with no intention to unduly delay the proceedings. The parties further stipulate that the Court's Scheduling Order shall be modified accordingly.

ORDER

APPROVED AND SO ORDERED.