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

ALLISON CLAIRE, Magistrate Judge.

IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that the time for Defendant to respond to Plaintiff's Motion for Summary Judgment be extended from June 28, 2019 to August 16, 2019. This is Defendant's first request for extension. Good cause exists to grant Defendant's request for extension. In late April and May, Counsel for Defendant (Counsel) had four family tragedies, including the loss of her cousin, his wife, an uncle and a close family friend. Due to the back-to-back deaths, Counsel took time off to attend out of town funeral and prayer services. Counsel also has taken additional leave to care for her elderly mother, who became ill and required surgery in mid-May and another surgery in early June. In addition, Counsel also has over 100+ active social security matters, which require two or more dispositive motions until mid-August. As well as a Ninth Circuit brief that requires several levels of review due in early August. As such, Counsel needs additional time to adequately review the transcript and properly respond to Plaintiff's Motion for Summary Judgment. The parties further stipulate that the Court's Scheduling Order shall be modified accordingly. Defendant makes this request in good faith with no intention to unduly delay the proceedings. Counsel apologizes for the belated request, but made her request as soon as reasonably practicable following her leave. The parties further stipulate that the Court's Scheduling Order shall be modified accordingly.

ORDER

APPROVED AND SO ORDERED.