STIPULATION TO EXTEND TIME TO FILE MOTION FOR REVERSAL AND/OR REMAND

(SECOND REQUEST)

RICHARD F. BOULWARE, II, District Judge.

Plaintiff Thomas M. Bartz ("Plaintiff") and defendant Nancy A. Berryhill, Commissioner of Social Security ("Defendant"), through their undersigned counsel of record, hereby stipulate, subject to the approval of the Court, to extend the time for Plaintiff to file Plaintiff's Motion for Reversal and/or Remand to April 24, 2017; and that Defendant shall have until May 24, 2017, to file her opposition, if any is forthcoming. Any reply by plaintiff will be due June 14, 2017.

As the Court is aware, after a 5 year battle with terminal stage 4 cancer Plaintiff's Counsel's Spouse of the associate, who this matter is assigned to, passed away on September 30, 2016. The aftermath of this traumatic event on both Counsel and his 9 year old son and 7 year old daughter was immeasurable. Compounding the impact of this loss is the fact that Counsel's spouse was a former employee at Counsel's Law Firm and her death was far reaching in its impact on Counsel's professional life as well. Due to the death, the subsequent holiday period, and the need to find a permanent caregiver and the required time to acclimate his children to that presence during his absence to meet his professional obligations, Counsel requires the additional time to prepare and file her motion for summary judgment.

Counsel for plaintiff does not anticipate this extraordinary request for more time to become the rule and recognizes it is the extraordinary exception and sincerely apologizes to the court for any inconvenience this may have had upon it or its staff.

IT IS SO ORDERED:

CERTIFICATE OF SERVICE FOR CASE NUMBER 2:16-CV-02073-RFB-PAL

I hereby certify that I electronically filed the foregoing with the Clerk of the Court for this court by using the CM/ECF system on March 23, 2017.

I certify that all participants in the case are registered CM/ECF users and that service will be accomplished by the CM/ECF system.