STIPULATION AND [PROPOSED] ORDER TO EXTEND BRIEFING SCHEDULE

ALLISON CLAIRE, Magistrate Judge.

IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, to extend Defendant's time to file her response to Plaintiff's summary judgment motion with the Court by 30 days to May 29, 2019, and that all other scheduling dates set forth in the Court's Case Management Order shall be extended accordingly. This is Defendant's first request for an extension of time in this matter and she requests it in good faith and without any intent to prolong proceedings unduly.

There is good cause for this extension request because counsel for Defendant is currently responsible for performing a range of tasks that preclude drafting the Commissioner's response to Plaintiff's summary judgment motion by April 29, 2019. In particular, because a supervisor in Defendant's Office of the General Counsel, Region IX was serving as a juror on a five-week trial, counsel for Defendant assumed shared responsibility for overseeing the office's program litigation workload throughout Nevada, California, Arizona, and Hawaii until approximately the second week of April. Counsel for Defendant is presently conducting substantive and logistical preparation for a hearing scheduled from April 30-May 2, 2019 in personnel litigation pending before the Merit Systems Protection Board. Counsel for Defendant also remains responsible for drafting briefs in other Social Security matters before the district courts within the Ninth Circuit, including three briefs due in the next twelve days; negotiating (or litigating) attorney fee matters pursuant to the Equal Access to Justice Act; and assisting with the training of newly hired attorneys in the agency's Office of the General Counsel, Region IX. This extension will enable counsel for Defendant to fully review the record and Plaintiff's summary judgment motion and, if warranted, evaluate the defensibility of the Commissioner's position.

Counsel for Defendant apologizes to Plaintiff and the Court for any inconvenience caused by this delay.

ORDER

APPROVED AND SO ORDERED