STIPULATION AND ORDER TO EXTEND DISPOSITIVE MOTION DEADLINES

(FIRST REQUEST)

GEORGE FOLEY, JR., Magistrate Judge.

Pursuant to LR 6-1 and LR 26-4, the parties, by and through their respective counsel of record, hereby stipulate and request that this Court extend the deadline for Defendant to file its Motion for Summary Judgment in the above-captioned case from the current deadline of May 29, 2018 up to and including June 15, 2018.

This Request for an extension of time is not sought for any improper purpose or for the purpose of delay. This request for extension is based upon the following:

Counsel for Defendant has been ill, has family obligations the week the motion is due and will be out of town from June 8th through the 11th. This additional time is necessary to allow counsel for Defendant to finish drafting the motion for summary judgment in this matter and obtain necessary declarations.

Counsel for the parties have met and conferred on this topic and have agreed that, to best serve the interests of the parties and obviate the potential for future motion practice, the most efficient remedy is to reasonably extend the dispositive motion deadline for both parties based on the proposed new deadline of June 15, 2018.

WHEREFORE, the parties respectfully request that this Court extend the time for the parties to file their dispositive motions from the current deadline of May 29, 2018 up to and including June 15, 2018, with the respective deadlines for filing the Response and Reply to be adjusted accordingly.

IT IS SO ORDERED.