STIPULATION TO EXTEND TIME TO FILE MOTION FOR REMAND

(FIRST REQUEST)

PEGGY A. LEEN, Magistrate Judge.

Plaintiff Wanda R. Clemons and Defendant Nancy A. Berryhill, Acting Commissioner of Social Security, through their undersigned attorneys, stipulate, subject to this court's approval, to extend the time by 45 days from November 23, 2018 to January 7, 2019 for Plaintiff to file a Motion for Remand, with all other dates in the Court's Scheduling order extended accordingly. This is Plaintiff's first request for an extension. This request is made at the request of Plaintiff's counsel to allow additional time to fully research the issues presented. Counsel's mother has been fighting a losing battle with Systemic Lupus Erythematosus that has required multiple surgeries these past two years due inflammation affecting the kidneys and lungs. Counsel's mother has undergone several kidney surgeries since February 11, 2018. Counsel's mother continues with her recovery process that has required Counsel to take time off to attend her mother's financial and physical needs which has impacted a heavy briefing and hearing calendar. In addition, Counsel has been fighting off a flu for since last week.

This is not an ordinary circumstance for Counsel and Counsel sincerely apologizes to the Court for any inconvenience this may have cause. Counsel's firm has hired another associate to help Counsel during this difficult time. Counsel sincerely apologizes to the court and its staff for any inconvenience this may have.

IT IS SO ORDERED.