STIPULATION AND PROPOSED ORDER FOR AN EXTENSION OF TIME OF 14 DAYS FOR DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT

EDMUND F. BRENNAN, Magistrate Judge.

IT IS HEREBY STIPULATED, by and between the parties, through their respective counsel of record, that Defendant shall have an extension of time of 14 additional days to respond to Plaintiff's motion for summary judgment. The current due date is December 17, 2018. The new due date will be December 31, 2018.

This is Defendant's second request for an extension of time and in this case overall. There is good cause for this request. Since the granting of Defendant's first request for an extension of time, Defendant's counsel fell ill for about two and a half weeks and was incapacitated and unable to work multiple days. Defendant's counsel has continued to address her full workload and backlog of district court cases and other matters, including six district court briefs, an EEOC appeal, objection to a bankruptcy discharge, and an EEOC hearing request and related settlement discussions, between the date she recovered, around November 15, 2018, to today's date, December 14, 2018. Defendant's counsel also shifted or tried to shift her other work besides this case, with some requests to extend (for at least two other cases) to after the December 17, 2018 due date of this case, denied or limited. While Defendant's counsel is in the process of continuing to shift her cases and have some of her cases reassigned to avoid further delay of her cases, she still needs additional time to fully review the record and research the issues presented by Plaintiff's motion for summary judgment in this case.

Thus, Defendant is respectfully requesting additional time up to and including December 31, 2018, to respond to Plaintiff's motion for summary judgment. This request is made in good faith with no intention to unduly delay the proceedings.

ORDER

APPROVED AND SO ORDERED.