STIPULATION AND PROPOSED ORDER FOR AN EXTENSION OF TIME OF 30 DAYS FOR PLAINTIFF'S REPLY TO DEFENDANT'S OPPOSITION TO PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT AND PLAINTIFF'S OPPOSITION TO DEFENDANT'S CROSS-MOTION FOR SUMMARY JUDGMENT

CAROLYN K. DELANEY, Magistrate Judge.

IT IS HEREBY STIPULATED by and between the parties, through their respective counsel of record, that Plaintiff shall have an extension of time of an additional thirty (30) days to file his Reply to Defendant's Opposition to Plaintiff's Motion for Summary Judgment and Opposition to Defendant's Cross-Motion for Summary Judgment in the present case. This is the first continuance sought by Plaintiff with regard to this Reply/Opposition. The current due date is April 11, 2018. The new due date will be May 11, 2018.

Good cause exists for this request. Plaintiff's counsel has been preparing for and attending hearings (Plaintiff's counsel attended a hearing earlier this week), and has hearings to prepare for and attend as soon as next week (the week this Reply/Opposition is due). Further, Plaintiff's counsel has recently been assigned multiple files, and will be assigned more in the near future, all of which require detailed review to ensure that any deadlines are met.

Therefore, Plaintiff is respectfully requesting additional time up to and including May 11, 2018, to prepare his Reply to Defendant's Opposition to Plaintiff's Motion for Summary Judgment and Opposition to Defendant's Cross-Motion for Summary Judgment. This request is made in good faith and with no intention to unduly delay the proceedings.

ORDER

Based on the foregoing stipulation and good cause appearing therefore, IT IS HEREBY ORDERED:

Plaintiff's Reply to Defendant's Opposition to Plaintiff's Motion for Summary Judgment and Opposition to Defendant's Cross-Motion for Summary Judgment must be filed by May 11, 2018.