STIPULATION AND ORDER TO EXTEND BRIEFING SCHEDULE

CAROLYN K. DELANEY, Magistrate Judge.

IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, to extend Defendant's time to file her summary judgment motion with the Court by 35 days to October 9, 2018, 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 has workload issues that preclude filing her cross-motion by September 4, 2018. In particular, counsel for Defendant is currently responsible for performing an extensive range of tasks, such as: drafting briefs and summary judgment motions (including five due in the next three weeks) in Social Security cases before the district courts within the Ninth Circuit, negotiating (or litigating) attorney fee matters pursuant to the Equal Access to Justice Act before the district courts within the Ninth Circuit; drafting a post-hearing brief for an arbitration proceeding involving the agency and one of the agency's collective bargaining units; and assisting with implementing the terms of the class action settlement reached in Hart v. Berryhill (N.D.Cal. No. 3:15-cv-623-JST). Counsel for Defendant has also been out of the office for significant portions of the month of August in order to deliver presentations to the agency's Office of Hearing Operations.

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

ORDER

APPROVED AND SO ORDERED.