STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF BRIEFING SCHEDULE ON DEFENDANT'S MOTION FOR JUDGMENT ON THE PLEADINGS OR, IN THE ALTERNATIVE, FOR A STAY

RICHARD F. BOULWARE, II, District Judge.

Plaintiff Kirby Spencer ("Plaintiff"), by and through his attorneys Craig K. Perry & Associates and McGuire Law, P.C., and Defendant Kohl's Department Stores, Inc. ("Defendant"), by and through its attorneys Ballard Spahr LLP and Kelley Drye & Warren LLP, hereby stipulate and agree, pursuant to L.R. IA 6-1 and 6-2, and L.R. 7-1, and subject to this Court's approval, to an extension of time to September 24, 2018 for Plaintiff to respond to Defendant's Motion for Judgment on the Pleadings or, in the Alternative, for a Stay (ECF Nos. 89, 90) ("Motion for Judgment"), and for an extension of time to October 22, 2018 for Defendant to file its reply in support of its Motion for Judgment.

This Stipulation is made in good faith and not for the purpose of delay or for any other improper purpose. Plaintiff's response to Defendant's Motion for Judgment is currently due August 30, 2018 (ECF No. 89). Plaintiff seeks the additional time to properly address the issues raised in Defendant's Motion, as well as due to Plaintiff's counsel's significant other work commitments and travel over the upcoming weeks, including the Labor Day holiday. Defendant seeks the additional time to file its reply to properly address the issues likely to be raised in Plaintiff's Opposition brief. This is the first request for extension of time related to Defendant's Motion for Judgment.

WHEREFORE, Plaintiff Kirby Spencer and Defendant Kohl's Department Stores, Inc. hereby stipulate and respectfully request that the Court enter an Order: (i) extending the deadline for Plaintiff to file his response to Defendant's Motion for Judgment to September 24, 2018; and (ii) extending the deadline for Defendant to file its Reply in support of the Motion for Judgment to October 22, 2018.

Pursuant to Stipulation, IT IS SO ORDERED.