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

CARL W. HOFFMAN, 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 Remand be extended from August 29, 2018 to August 30, 2018. This is Defendant's third request for extension. Good cause exists to grant Defendant's request for extension. Following the third death in the last three months in Counsel's family and an emergency family matter of Counsel's immediate family member that required emergency stay and surgery during the same week, Counsel took some additional personal leave last week and was out of the office to recoup from the several family tragedies. Counsel also has over 85+ pending social security cases, which require two or more dispositive motions a week until mid-October, as well as a pending Ninth Circuit case (due in early October) and several civil rights matters that require immediate investigation. Due to current workload demands and unanticipated leave, Counsel did not have sufficient time to finalize Defendant's response. As such, Defendant needs additional time to adequately review the transcript and properly respond to Plaintiff's Motion for Remand. Defendant makes this request in good faith with no intention to unduly delay the proceedings. Counsel apologizes for the belated request, but did not anticipate taking additional leave. The parties further stipulate that the Court's Scheduling Order shall be modified accordingly.

ORDER

APPROVED AND SO ORDERED.