JOINT SITPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT.

ALLISON CLAIRE, Magistrate Judge.

IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that the time for responding to Plaintiff's Opening Brief be extended from June 20, 2019 to August 8, 2019. This is Defendant's second request for extension. Good cause exists to grant Defendant's request for extension. As the Court is aware, Counsel had multiple family tragedies in the month of April and May, including the loss of her cousin, his wife, an uncle, and then a close family friend in mid-May. As a result, Counsel attended funeral and prayer services and took care of her elderly mother, who subsequently became ill. Counsel's mother also had two surgeries in late May and early June, and Counsel was also out as her mother's primary caregiver following her surgeries. Good cause also exits as Counsel also has over 100+ active social security matters, which require two or more dispositive motions per week until mid-August. In addition, Counsel has three pending Ninth Circuit matters due in early August. Due to heavy caseload and unexpected leave, Counsel needs additional time to adequately review the transcript and properly respond to Plaintiff's Motion for Summary Judgment. The parties further stipulate that the Court's Scheduling Order shall be modified accordingly. Defendant makes this request in good faith with no intention to unduly delay the proceedings. Counsel apologizes for the belated request, but made her request as soon as reasonably practicable, as she has been on sick/personal leave.

Respectfully submitted,

ORDER

APPROVED AND SO ORDERED: