STIPULATION AND ORDER TO EXTEND BRIEFING SCHEDULE

CRAIG M. KELLISON, Magistrate Judge.

IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, to extend Defendant's time to file her cross-motion for summary judgment with the Court by 30 days to September 28, 2016, and that all other scheduling dates set forth in the Court's Case Management Order shall be extended accordingly. This is Defendant's second request for an extension of time in this matter1, and she requests it in good faith and without any intent to prolong proceedings unduly.

There is good cause for this extension request. First, a 30-day extension is necessary because counsel for Defendant was (or will be) out of the office for significant portions of the period between August 15 and 29, 2016, and requires additional time to adequately research and analyze the factual record and Plaintiff's legal claims. Second, counsel for Defendant has workload issues that preclude filing the summary judgment motion by August 29, 2016. Specifically, in addition to the work-related travel and personal leave referenced above, counsel for Defendant is responsible for drafting various pleadings before the district courts within the Ninth Circuit, drafting an appellate pleading in a Social Security matter before the Ninth Circuit, and negotiating or litigating attorney fee matters pursuant to the Equal Access to Justice Act. Counsel for Defendant is also currently responsible for conducting discovery and drafting briefs personnel litigation before the Equal Employment Opportunity Commission and Merit Systems Protection Board.

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

ORDER

APPROVED AND SO ORDERED.