STIPULATION AND PROPOSED ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE AND RELATED DEADLINES

NATHANAEL COUSINS, District Judge.

1. This is an ERISA long term disability case in which the case management conference is set for November 12, 2014.

2. The complaint in this matter was filed on October 29, 2013.

3. Pursuant to plaintiff's requests, the Court has granted several continuances of the case management conference so that the parties could engage in settlement discussions.

4. As of today's date, discussions are ongoing between plaintiff's counsel and in-house counsel for defendants. These discussions are further detailed in the status report plaintiff filed on September 11, 2014. (See, Dk. # 21.)

5. Pursuant to the Court's previous order of July 9, 2014, defendants have been served with the complaint (by way of waivers of service filed on September 2, 2014). They filed their answer to the complaint on November 3, 2014.

6. As noted above, the case management conference is currently set for November 12, 2014.

7. The administrative record in this case consists of approximately three thousand pages of documents. Defense counsel, being recently retained in this matter, requires further time to familiarize themselves with its contents.

8. Additionally, as noted above, negotiations between plaintiff's counsel and defendants' in-house counsel are continuing, and the parties would like to continue their efforts to settle this matter without incurring unnecessary legal fees.

9. In light of the forgoing, the parties jointly request that the case management conference and associated dates be continued for approximately sixty (60) additional days. Respectfully submitted,

PROPOSED ORDER

Good cause having been shown, the Court hereby continues the case management conference until. The parties shall file a joint case management conference statement by.

IT IS SO ORDERED.