STIPULATION AND PROPOSED ORDER FOR FIRST EXTENSION OF TIME TO FILE REPLY

KANDIS A. WESTMORE, Magistrate Judge.

The parties hereto, by and through their undersigned attorneys, hereby stipulate that Plaintiff, Jerry Huggins, shall have an additional 30 days, until September 19, 2018, in which to file and serve a reply in this action. This is the first stipulation for extended time requested by Plaintiff for the reply in this matter. This is necessary due to an unexpected substitution of counsel made necessary by prior extensions in this case as well as the time taken by the Appeals Council to decide whether or not to agree to voluntary remand.

Specifically, Plaintiff's prior attorney (Joanna Parnes) reviewed the record, drafted the motion for summary judgment, and intended to draft and file the reply prior to going on maternity leave on August 1, 2018, but was unable to do so after Defendant's third extension. Accordingly, the undersigned recently substituted in as counsel. Counsel for Defendant considered voluntary remand of this case, but the case was not suitable for remand. Counsel for Defendant notified Plaintiff's counsel regarding the decision regarding voluntary remand on August 15, 2018. In the interest of efficiency, the undersigned began reviewing the record and drafting the reply after she heard back from Counsel for Defendant regarding remand. For these reasons, and due to preexisting as well as additional unexpected and unavoidable workload demands, an extension is necessary for Plaintiff to sufficiently review the record and draft the reply.

[PROPOSED] ORDER:

PURSUANT TO THE STIPULATION, IT IS SO ORDERED