STIPULATION AND PROPOSED ORDER TO EXTEND THE PRETRIAL ORDER DEADLINE TWENTY-ONE (21) DAYS TO MAY 17, 2018

(FIRST REQUEST)

RICHARD F. BOULWARE, II, District Judge.

Pursuant to LR IA 6-1 and 6-2, it is hereby agreed to and stipulated between Plaintiff/Counterclaim Defendant Boston Dental Group, LLC ("Boston Dental"), by and through its counsel, Michael R. Mushkin & Associates P.C. and Borghese Legal, Ltd., on the one hand, and Defendant/Counterclaim Plaintiff Affordable Care, LLC ("Affordable Care"), by and through its counsel, Kolesar & Leatham and Barack Ferrazzano Kirschbaum & Nagelberg LLP, on the other hand, to a twenty-one (21) day extension of the April 26, 2018 Joint Pretrial Order deadline, until May 17, 2018, for the purpose of allowing the parties to focus on settlement negotiations, as further set forth herein. This is the first stipulation for extension of time to extend the Joint Pretrial Order deadline.

The parties have been diligently working to comply with the April 26, 2018 Joint Pretrial Order deadline and have also been simultaneously engaged in settlement negotiations. The parties now seek a brief twenty-one (21) day extension of the Joint Pretrial Order deadline in order to focus on settlement. The litigation of this matter will be best served by the proposed extension.

Preparation of the Joint Pretrial Order is time-consuming and the parties would like to put their effort into settlement. Further, the costs that would be incurred in finalizing a Joint Pretrial Order could be better used to resolve the dispute. There is good cause to grant the parties' first stipulation for extension of time because the parties have been diligent in preparing the Joint Pretrial Order and are engaged in serious settlement negotiations. See Fernandez v. N.V., Case No. 2011 WL 3957612 at *2 (Dist. Nev. Sept. 6, 2011) (granting motion for extension of time to file pretrial brief because parties engaged in settlement negotiations). The parties do not anticipate that a brief twenty-one (21) day extension of time to submit the Joint Pretrial Order will affect potential trial dates.

Accordingly, the parties stipulate that the deadline for the Joint Pretrial Order be extended for twenty-one (21) days from April 26, 2018 to May 17, 2018.

IT IS SO STIPULATED.

ORDER

IT IS SO ORDERED.