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

WILLIAM H. ORRICK, District Judge.

IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record that the time for responding to Plaintiff's Motion Summary Judgment be extended from May 27, 2019 to July 9, 2019. This is Defendant's first request for extension. Good cause exists to grant Defendant's request for extension. Counsel for Defendant (Counsel) had multiple family tragedies last month, including the death of her two cousins, and uncle and was out of the office attending prayer and funeral services. Counsel also has been out of the office taking care of her elderly mother, who is schedule for two surgeries this month, and also out due to her ongoing health issues. In addition, Counsel also has over 100+ active social security matters, which require two or more dispositive motions per week until the mid-July. Due to heavy caseload and unexpected leave, Counsel fell behind on her work and 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 also has been out of the office.

ORDER

APPROVED AND SO ORDERED.