JOINT STIPULATION FOR EXTENSION OF TIME AND [PROPOSED ORDER]

PEGGY A. LEEN, 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 Remand be extended from September 13, 2018 to October 29, 2018. This is Defendant's first request for extension. Good cause exists to grant Defendant's request for extension. Counsel was recently out on intermittent medical leave and bereavement leave for the past few months. Counsel has over 75+ active matters, which requires two or more dispositive motions a week until mid-September. In addition, Counsel has active civil rights and representative misconduct matters that require immediate investigation. Counsel also has a Ninth Circuit brief due on October 1, 2018, which requires multiple levels of review. Due to Counsel's unexpected leave, Counsel became behind on her heavy workload. As such, Counsel needs additional time to adequately review the transcript and properly respond to Plaintiff's Motion for Summary Judgment. Counsel for Defendant is also expected to be out of the office from September 3, 2018 through September 9, 2018 and September 21, 2018 through September 27, 2018. 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.