STIPULATION TO EXTEND TIME OF TIME TO FILE MOTION FOR REMAND/REVERSAL

(FIRST REQUEST)

GEORGE FOLEY, Magistrate Judge.

Plaintiff Manuel L. Garcia 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 from May 2, 2019, to May 31, 2019, for Plaintiff to send his Motion for Remand/Reversal 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.

Plaintiff's counsel currently has three motions due the week this motion is due. Counsel has at least one District Court motion due each week until May 31, in addition to it seven reply briefs, and 11 Appeals Council briefs. Council will also be taking a pre-planned leave one-week prior to the proposed due date. Also, in May, plaintiff's counsel also has three out of county hearings requiring significant travel time. An extension to May 31, 2019, will allow counsel to fully research the issues presented.

IT IS SO ORDERED.

[PROPOSED] ORDER EXTENDING BRIEFING SCHEDULE

Based upon the stipulation of the parties, and for cause shown,

IT IS HEREBY ORDERED, that Plaintiff shall have an extension of time, to and include May 31, 2019, in which to file Plaintiff's MOTION FOR REVERSAL AND/OR REMAND; and that all other deadlines set forth in the April 1, 2019 Case Management Order shall be extended accordingly. IT IS SO ORDERED.