JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME FOR DEFENDANT TO RESPOND TO PLAINTIFF'S MOTION FOR REMAND

NANCY J. KOPPE, 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 from August 20, 2018 to October 4, 2018. This is Defendant's first request for extension. Good cause exists to grant Defendant's request for extension. Counsel had three deaths in her family in June, July and now August, as well as a family medical emergency of an immediate family member. As such, Counsel has been out on leave to attend to the several funeral and prayer services and expects to take additional bereavement leave for the recent family death. In addition, Counsel also has over 85+ pending social security cases, which require two or more dispositive motions a week until mid-September, a pending Ninth Circuit matter, and several non-litigation civil rights and representative misconduct matters that require prompt attention and investigation. Counsel is also expected to be on vacation leave during the last week of September. Due to current workload demands and unanticipated and upcoming leave, Counsel needs additional time to adequately review the transcript and properly respond to Plaintiff's Motion for Remand. 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

APPROVED AND SO ORDERED.