STIPULATION AND ORDER RE ADDITIONAL TIME FOR PLAINTIFF TO FILE MOTION FOR ATTORNEYS' FEES AND COSTS TO ALLOW TIME FOR THE PARTIES TO CONTINUE TO MEET AND CONFER

TROY L. NUNLEY, District Judge.

Plaintiff Otilia Sullivan ("Plaintiff") and Defendant The Prudential Insurance Company of America ("Prudential") enter this Stipulation based on the following:

WHEREAS, on October 22, 2014 the Court entered the Parties' Proposed Judgment in favor of Plaintiff. (See Doc. No. 68). Plaintiff, as the prevailing party in this litigation, may apply to the Court for an award of attorneys' fees and recovery of costs of action. Pursuant to the Court's October 22, 2014 order, any application for an award of attorneys' fees and recovery of costs of action is due to be filed no later than December 6, 2014. (See Doc. No. 68).

WHEREAS, Plaintiff has submitted detailed information to Prudential for its review in support of its motion for an award of attorneys' fees and costs. Prudential is in the process of reviewing this information and the Parties have been meeting and conferring regarding the issue.

WHEREAS, the Parties have been working together and have diligently met and conferred in good faith in an effort to reach a resolution on attorneys' fees and costs without court intervention. The Parties represent that due to unavailability of counsel and their clients, they will not be in a position to complete their meet and confer efforts prior to the December 6, 2014 deadline to file a motion.

Therefore, the Parties, by and through their counsel of record, stipulate and agree that Plaintiff shall have an additional forty-five (45) days to file any motion for an award of attorneys' fees and recovery of costs in this action. Plaintiff's motion for attorneys' fees and costs shall be filed no later than January 20, 2015.

The foregoing proposed stipulation is respectfully submitted.

IT IS SO STIPULATED.

IT IS SO ORDERED.