JOINT STIPULATION FOR EXTENSION OF TIME TO FILE DEFENDANT'S NOTICE OF VOLUNTARY REMAND OF THE CASE OR CROSS-MOTION TO AFFIRM.

CARL W. HOFFMAN, 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 approximately forty-six (46) days from June 5, 2017 to July 21, 2017. This is Defendant's first request for extension. Good cause exists to grant Defendant's request for extension. Additional time is required as counsel for Defendant has over 50+ active matters, of which two dispositive motions are required on the same date as the current deadline. Counsel for Defendant also had to take unexpected family medical leave earlier this month to care for her elderly mother who just had surgery. As a result, Counsel for Defendant needs additional time to respond to her pending matters resulting from the unanticipated family medical leave. In addition, due to the nature of this case and voluminous paper transcript, Counsel respectfully requests additional time to respond to Plaintiff's Motion for Summary Judgment in order to adequately research, analyze and respond to the issues presented by Plaintiff. Defendant makes this request in good faith with no intention to unduly delay the proceedings. Plaintiff has no objection to the requested relief.

The parties further stipulate that the Court's Scheduling Order shall be modified accordingly.

IT IS SO ORDERED.