HAYWOOD S. GILLIAM, Jr., District Judge.
People with Disabilities, Inc. ("Plaintiff") and Defendant Carolyn Colvin, Acting Commissioner of Social Security ("Defendant"), by and through their respective counsel, make the following representations and stipulate and agree as follows:
1. On June 22, 2016, Plaintiff filed its Second Amended Complaint in this action. See Dkt. No. 30.
2. On the same date, counsel for Defendant requested a thirty-seven-day extension of time, up to and including August 12, 2016, to respond to the Second Amended Complaint. Plaintiff has agreed to this request and Plaintiff's counsel has also indicated that he will be unavailable from August 14, 2016 to August 29, 2016.
3. Based on the foregoing, the parties agree that should Defendant file a motion to dismiss Plaintiff's Second Amended Complaint, Plaintiff will have thirty-seven days to file an opposition, up to and including September 19, 2016. The parties further agree that Defendant will have fourteen days to file her reply, up to and including October 3, 2016. Defendant will notice her motion for an appropriate hearing date based on this proposed briefing schedule.
4. The Court has allowed two prior extensions of time related to Defendant's response to Plaintiff's original Complaint and the parties briefing schedule related to Defendant's motion to dismiss Plaintiff's First Amended Complaint. See Dkt. Nos. 15, 21.
5. There are no dates set in this case. Accordingly, the requested time modification will have not affect any date set by the Court.
Plaintiff and Defendant's Stipulation and Proposed Order Continuing Deadline for Defendant's Responsive Pleading and Proposed Briefing Schedule is hereby