JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF PLAINTIFF AND COUNTER-DEFENDANT HYDROS'S TIME TO FILE MOTION FOR ATTORNEY'S FEES

JON S. TIGAR, District Judge.

STIPULATION

Pursuant to Civil Local Rule 6-1, Plaintiff and Counter-Defendant Hydros Bottle LLC ("Hydros") and Defendant and Counterclaimant Stephen Gould Corporation ("SGC") hereby stipulate and agree as follows:

WHEREAS, on April 3, 2017, the Clerk of the Court entered its Rule 68 Judgment in favor of Hydros and against SGC;

WHEREAS, pursuant to FRCP Rule 54 and Local Rule 54, Hydros and SGC have been meeting and conferring to resolve the issue of the amount of attorney's fees;

WHEREAS, Hydros and SGC also have been meeting and conferring to resolve the amount of prejudgment interest due to Hydros;

WHEREAS, Hydros's motion to determine the amount of attorney's fees is due today, April 17, 2017;

WHEREAS, Hydros's motion to determine the amount of prejudgment interest and thereby to amend the judgment under FRCP Rule 59(e) to include that amount is due no later than May 1, 2017;

WHEREAS, the parties wish to have additional time to discuss the attorney's fees and prejudgment interest issues in an effort to resolve those matters without involving the Court, if feasible;

WHEREAS, the parties agree that by entering into this stipulation, Hydros and SGC are not waiving any rights, claims, or defenses; and

WHEREAS, there have been no previous time modifications Hydros's time to move to determine the amount of attorney's fees due to Hydros and the change will not alter the date of any event or any deadline already fixed by Court order.

THEREFORE, IT IS HEREBY STIPULATED, pursuant to Local Rules 6-2 and 54-5, by and between the parties, and through their respective attorneys of record and subject to order of the Court, that Hydros shall have up to and including May 1, 2017, the same day as its motion to determine prejudgment interest is due, to move for a determination of the amount of attorney's fees to be awarded and/or otherwise move with respect to its request for attorney's fees.

CIVIL L.R. 5-1(i) ATTESTATION

I, Thomas B. Watson, hereby attest that I have been authorized by Christopher T. Holland, counsel for Defendant and Counterclaimant Stephen Gould Corporation, to execute on his behalf this Stipulation.

[PROPOSED] ORDER

After consideration of the parties' Stipulated Request for an Order for Extension of Plaintiff and Counter-Defendant Hydros's Time to File Motion for Attorney's Fees, and good cause appearing,

IT IS HEREBY ORDERED THAT:

IT IS SO ORDERED.