STIPULATION AND ORDER TO EXTEND BRIEFING SCHEDULE

DENNIS M. COTA, Magistrate Judge.

IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, to extend Defendant's time to file her response to Plaintiff's summary judgment motion with the Court by 30 days to April 8, 2019, and that all other scheduling dates set forth in the Court's Case Management Order shall be extended accordingly. This is Defendant's first request for an extension of time in this matter and she requests it in good faith and without any intent to prolong proceedings unduly.

There is good cause for this extension request because counsel for Defendant is currently responsible for performing a range of tasks that preclude drafting the Commissioner's response to Plaintiff's summary judgment motion by March 8, 2019, such as: drafting a brief in a Social Security matter before the Ninth Circuit; negotiating (or litigating) attorney fee matters pursuant to the Equal Access to Justice Act before the district courts within the Ninth Circuit; assisting with the training of newly hired attorneys in the agency's Office of the General Counsel, Region IX; conducting discovery in personnel litigation pending before the Equal Employment Opportunity Commission and Merit Systems Protection Board; and assisting with implementing the terms of the class action settlement reached in Hart v. Berryhill (N.D.Cal. No. 3:15-cv-623-JST). This extension will enable counsel for Defendant to fully review the record and Plaintiff's summary judgment motion and, if warranted, evaluate the defensibility of the Commissioner's position.

Counsel for Defendant apologizes to Plaintiff and the Court for any inconvenience caused by this delay.

ORDER

APPROVED AND SO ORDERED