STIPULATION AND ORDER TO EXTEND BRIEFING SCHEDULE

GARY S. AUSTIN, Magistrate Judge.

IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, to extend Defendant's time to file her brief with the Court by 30 days to November 21, 2018, 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 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 brief by October 22, 2018. In particular, counsel for Defendant is currently responsible for performing an extensive range of tasks, such as: preparing for an oral arguments in three Social Security cases before the District of Hawaii at the end of the month, drafting briefs and summary judgment motions 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 (including one brief due next week); preparing and delivering a presentation to the Social Security Administration's Office of Hearing Operations; 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). Also, counsel for Defendant presented an oral argument to the Ninth Circuit in a Social Security case on October 10, 2018; substantive preparation and travel to Honolulu, Hawaii for this argument has hindered review of the record and preparation of the responsive brief in the instant case.

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

IT IS SO ORDERED.