JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO MODIFY BRIEFING SCHEDULE AND EXTEND DEFENDANT'S TIME TO RESPOND TO PLAINTIFF'S MOTION FOR ATTORNEYS FEES PURSUANT TO THE EQUAL ACCESS TO JUSTICE ACT (EAJA).

(First Extension Request)

RICHARD F. BOULWARE, II, District Judge.

IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that the time for responding to Plaintiff's Motion for Attorneys Fees Under Equal Justice Access Act (EAJA)(Dkt No. 26) be extended from March 11, 2019 to May 11, 2019. Good cause exists to grant Defendant's request for extension. Counsel for Defendant (Counsel) apologizes for the belated request for extension, but seeks an extension of time as Counsel was out of the office on intermittent sick leave for over two and half weeks in early March with the flu/pneumonia and did not accurately calendar Defendant's response to Plaintiff's Motion for Attorneys Fees Under EAJA, which was due at the same time. Good cause also exists, as Counsel has over 80+ active social security matters that require two or more dispositive motions per week until mid-May. Due to Counsel's workload and unexpected leave, Counsel needs additional time to properly respond to Plaintiff's Motion and/or engage in settlement negotiations to settle the matter without further motion practice. Defendant makes this request in good faith with no intention to unduly delay the proceedings. The parties further stipulate that the Court's Scheduling Order shall be modified accordingly.

ORDER

IT IS SO ORDERED.