UNOPPOSED MOTION FOR EXTENSION OF TIME FOR DEFENDANT TO FILE CROSS-MOTION PLAINTIFF'S MOTION FOR REMAND/REVERSAL

GEORGE FOLEY, Jr., Magistrate Judge.

Defendant Carolyn W. Colvin, Acting Commissioner of Social Security ("Defendant") respectfully requests that the Court extend the time for Defendant to file her Cross-Motion to Affirm/Response to Plaintiff's Motion for Remand/Reversal (hereinafter "Defendant's response"), due on February 22, 2016, by 60 days, through and including April 22, 2016. This is the first extension sought in this case, and the first extension sought by Defendant.

There is good cause for this request. An extension of time is needed because Defendant's counsel will need more time to review and prepare Defendant's response, due to her heavy workload in the last month and continuing heavy workload in the next two months that cannot be covered by another attorney, including a full district court caseload, a Ninth Circuit appellate brief that has also been extended, mentoring a colleague on their first court oral argument in February, and preparing briefs and conducting discovery, including multiple depositions, for two Equal Employment Opportunity Commission (EEOC) cases in January and February, and again occurring in March and April for the second and a third EEOC case. This request is made in good faith with no intention to unduly delay the proceedings.

Counsel for Defendant conferred with Plaintiff's counsel, who has no opposition to this motion.

Respectfully submitted this 17th day of February.

IT IS SO ORDERED.