STIPULATION AND ORDER EXTENDING SETTLEMENT CONFERENCE AND TRIAL DATES AND RELATED DEADLINES

GARLAND E. BURRELL, Jr., District Judge.

This Stipulation and Order is based on the following facts:

1. Pursuant to the Court's January 28, 2014 Scheduling Order, the February 2, 2015 Stipulation and Order Extending Percipient Discovery Cutoff and Motion Dates, and the Court's July 2, 2015 Final Scheduling Order, this matter is scheduled for trial on September 15, 2015. A Settlement Conference is also scheduled for August 17, 2015 before the Honorable Kendall J. Newman.

2. The parties are currently in settlement negotiations and desire a 90-day extension of the settlement conference and trial dates, and related deadlines, to permit them to reach and finalize a settlement of this matter in its entirety, which will avoid the waste of judicial resources.

3. The parties believe there is a good chance of settling this matter and have been cooperating toward that end. These efforts have been somewhat protracted because Defendant is a public entity and all demands and counteroffers must be considered and approved by Defendant's Board.

4. Because of the time constraints imposed by the Board approval process, a 90-day extension is necessary to permit the parties to negotiate a settlement and complete the necessary settlement documentation.

5. In February 2015, the parties jointly requested a one-month extension of the percipient discovery cutoff and motion dates in this matter, which was granted by the Court. The trial date in this matter has never been continued, and the parties timely filed their Joint Pretrial Statement on June 29, 2015.

Based upon the foregoing, Plaintiff PAMELA JEAN BALSLY, (hereinafter referred to as "Plaintiff"), and Defendant MOUNTAIN COMMUNITIES HEALTHCARE DISTRICT (hereinafter "Defendant") hereby stipulate and seek an order of the Court continuing the trial in this matter for 90 days, with an attendant extension of the Settlement Conference and all previously-scheduled trial-related deadlines.

This Stipulation may be executed in counter-parts and faxed and/or authorized electronic signatures shall be deemed the same as an original execution.

PURSUANT TO THE ABOVE STIPULATION, IT IS HEREBY ORDERED THAT:

(1) The parties shall contact the clerk for Magistrate Judge Newman to reschedule the settlement conference to a mutually agreeable date and time.

(2) The trial commencement date and time in this matter is continued to January 12, 2016, at 9:00 a.m.