HAYWOOD S. GILLIAM, Jr., District Judge.
People with Disabilities, Inc. ("Plaintiff") and Defendant Carolyn Colvin, Acting Commissioner of Social Security ("Defendant"), by and through their respective counsel, make the following representations and stipulate and agree as follows:
1. On June 9, 2015, Plaintiff filed its Complaint in this action. See Dkt. No. 1.
2. On June 29, 2015, the U.S. Attorney's Office received a copy of Plaintiff's Complaint by certified mail. See Declaration of Ann Marie Reding ("Reding Decl."), ¶ 2.
3. On July 15, 2015, this case was set for an initial case management conference before Judge Haywood S. Gilliam for September 29, 2015, at 2:00 p.m., with a case management conference statement due to be filed on September 22, 2015. See Dkt. No. 14.
4. On August 10, 2015, Defendant requested a 30-day extension of time to respond to Plaintiff's Complaint, to which Plaintiff agreed. Reding Decl. ¶ 3.
5. In light of Defendant's request, the parties stipulate and agree that Defendant's response to Plaintiff's Complaint will be due on September 28, 2015. Id. at ¶ 4.
6. The parties further request that the initial case management conference be continued from September 29, 2015 to November 10, 2015 at 2:00 p.m. This continuance will allow enough time for a hearing on Defendant's motion to dismiss prior to the initial case management conference, should Defendant decide to file a motion in response to Plaintiff's Complaint. Id. at ¶ 5.
7. No prior extensions of time have been requested or granted. See id. at ¶ 6.
8. The only effect the requested time modification will have on this case is to delay the initial case management conference for six weeks. Id.
Plaintiff and Defendant's Stipulation and Proposed Order Continuing Deadline for Defendant's Responsive Pleading and Initial Case Management Conference is hereby