Filed: Nov. 28, 2018
Latest Update: Nov. 28, 2018
Summary: STIPULATION AND PROPOSED ORDER FOR EXTENSION OF TIME FOR DEFENDANT TO FILE OPPOSITION TO PLAINTIFF'S MOTION TO REMAND WILLIAM G. COBB , Magistrate Judge . IT IS HEREBY STIPULATED, by and between the parties, through their respective counsel of record, that Defendant shall have an extension of time of 60 days to file her opposition to Plaintiff's motion to remand, from November 29, 2018, to January 28, 2019. This is the first continuance in this case and sought by Defendant. There is good c
Summary: STIPULATION AND PROPOSED ORDER FOR EXTENSION OF TIME FOR DEFENDANT TO FILE OPPOSITION TO PLAINTIFF'S MOTION TO REMAND WILLIAM G. COBB , Magistrate Judge . IT IS HEREBY STIPULATED, by and between the parties, through their respective counsel of record, that Defendant shall have an extension of time of 60 days to file her opposition to Plaintiff's motion to remand, from November 29, 2018, to January 28, 2019. This is the first continuance in this case and sought by Defendant. There is good ca..
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STIPULATION AND PROPOSED ORDER FOR EXTENSION OF TIME FOR DEFENDANT TO FILE OPPOSITION TO PLAINTIFF'S MOTION TO REMAND
WILLIAM G. COBB, Magistrate Judge.
IT IS HEREBY STIPULATED, by and between the parties, through their respective counsel of record, that Defendant shall have an extension of time of 60 days to file her opposition to Plaintiff's motion to remand, from November 29, 2018, to January 28, 2019.
This is the first continuance in this case and sought by Defendant. There is good cause for this request. Defendant is seeking this extension due to Defendant's counsel's crowded briefing schedule with multiple deadlines on or around November 29, 2018, including cases that had been previously extended. In addition, at the filing of Plaintiff's motion for remand, new matters that were not previously anticipated and could not be shifted had arisen and have created some crowding of the briefing schedule around the due date of this case. Moreover, for about two and half weeks in early to mid-November, Defendant's counsel experienced sickness from a cold/virus that incapacitated her and inhibited her ability to work for multiple days. As a result, Defendant's counsel continues to address her existing workload and shift and prioritize her matters including this case, as needed, given the circumstances and as Defendant's counsel continues to address a full and growing workload for at least the next two months with variable degrees of ability to be adjusted.
Because of the factors described above, Defendant is requesting additional time up to and including January 28, 2019, to fully review the administrative record and research the issues presented by Plaintiff's motion to remand. This request is made in good faith with no intention to unduly delay the proceedings.
Therefore, with this Court's approval, the Court's scheduling order shall be extended by 60 days, so that Defendant may file her opposition to Plaintiff's motion to remand on or before January 28, 2019.
ORDER
PURSUANT TO THE STIPULATION, IT IS SO ORDERED.
