STIPULATION AND ORDER TO FILE AMENDED COMPLAINT FOR DAMAGES

HAYWOOD S. GILLIAM, JR., District Judge.

WHEREAS on August 16, 2019 Plaintiffs Brian Payne, Jesse Schwartz, Joshua Surrat, Jason Harre, and Jacob Ford filed a complaint alleging, inter alia, violations of their civil rights stemming from actions of the defendants; and

WHEREAS the parties sought early resolution of those claims prior to engaging in discovery, and were referred to Magistrate Judge Beeler for a settlement conference on January 15, 2020; and

WHEREAS two additional individuals with similar claims — Sean Haar and Kevin McGilbra — not presently named as plaintiffs, became known to the parties prior to the January 15 settlement conference, and by agreement of the parties were included in the settlement discussions so as to conserve judicial resources; and

WHEREAS the claims of all individuals were able to be settled, subject to the standard contingencies of board approvals; and

WHEREAS the parties desire to expedite the finalization of the settlement process by filing an amended complaint to include the claims of Messrs. Haar and McGilbra;

IT IS HEREBY STIPULATED by and between the parties hereto, and through their attorneys of record, that pursuant to Rule 15 of the Federal Rules of Civil Procedure, Plaintiffs may file a First Amended Complaint, a draft copy of which is attached hereto as Exhibit A.

The parties FURTHER STIPULATE that given the January 15, 2020 global conditional settlement of all 7 plaintiffs' claims, including Haar and McGilbra, responsive pleadings to the amended complaint by all defendants, and each of them, is stayed pending final approval of the conditional settlement by the relevant government agencies, and the filing of a stipulation for dismissal with prejudice of the entire action with each side to bear their own fees and costs.

ORDER

Good cause appearing, the Stipulation is SO ORDERED.