JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S MOTION FOR REVERSAL OR REMAND

PEGGY A. LEEN, Magistrate Judge.

IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that the time for responding to Plaintiff's Motion for Reversal and/or Remand be extended for one week from March 21, 2018 to March 28, 2018. This is Defendant's sixth request for extension. Good cause exists to grant Defendant's request for extension. Counsel for Defendant was sick and had chronic migraines, which impaired her vision at the time of her last extension request. Counsel continues to have chronic debilitating migraines and headaches on the date of the current filing deadline. As a result, Counsel became behind on her heavy caseload, which consists of over 75+ District Court cases, which require 2 or more dispositive motions per week and three pending Ninth Circuit matters. In addition, the Ninth Circuit matters require additional levels of review. Counsel has one of her Ninth Circuit matters due for review on the date of the current filing deadline, which she was unaware of at the time of the last extension request. Due to unanticipated leave and heavy workload, Counsel needs additional time to prepare a response to the Motion. Counsel apologizes for the belated request, but was unaware of scheduling conflicts in her other matters and did not expect to take additional sick leave from her chronic migraines. Defendant makes this request in good faith with no intention to unduly delay the proceedings.

The parties further stipulate that the Court's Scheduling Order shall be modified accordingly.

ORDER

APPROVED AND SO ORDERED.