STIPULATION AND ORDER REGARDING POST-TRIAL FILING DATES RELATED TO FEES AND COSTS, POST-TRIAL MOTIONS AND FOR TEMPORARY STAY OF EXECUTION

KIMBERLY J. MUELLER, District Judge.

In order to coordinate and streamline post-trial filing dates related to fees and costs, and in order to relieve all parties and the court from the associated workloads during the pendency of defendants' post-trial motions, and to further alleviate the uncertainty associated with the prospect of judgment enforcement in this matter, the parties, through their respective undersigned counsel, stipulate as follows:

1. Any and all initial filings related to plaintiffs' recovery of attorneys' fees and costs, including taxable and non-taxable costs, and whether due under 28 USC sections 1920, 1988, FRCP Rule 54(d), and Local Rules 292 and 293 or otherwise (herein "Cost Claims"), shall be filed together, on the same date, as set forth below. This Stipulation shall be without prejudice to plaintiffs' rights to file amended or supplemental filings related to the Cost Claims at a later date to the extent such filings may be permitted by the applicable rules and law or by leave of Court.

2. The parties stipulate that all filings related to the Cost Claims shall be filed by plaintiffs within 28 days after the date of entry of the Court's ruling on defendants' forthcoming post-trial motions, and that defendants shall have 14 days to oppose the Cost Claims. In the event that defendants timely file multiple post-trial motions and the Court disposes of the motions on different dates, that 28-day period will begin to run from the date of the Court's ruling on defendants' last pending timely filed post-trial motion.

3. Plaintiffs' written opposition papers responsive to defendants' post-trial motions shall be filed not later than fifty-six (56) days from the date said motions are filed. Defendants shall have twenty-one (21) days to file written reply papers.

4. Plaintiffs shall suspend and forebear any efforts to execute on the judgment from the date of this Stipulation up to and including 14 days after the last day for defendants to bring a timely appeal of the judgment. Forbearance on execution during the pendency of said appeal shall be subject to further agreements between the parties or proceedings before the Court as allowed by law. The parties mutually reserve all rights and privileges at law pertaining thereto.

5. This Stipulation shall be effective only upon entry of the Court's order adopting or approving same, and the parties hereby consent to the entry of an order based upon this Stipulation.

I hereby attest that I have on file all holograph signatures for any signatures indicated by a "conformed" signature (/s/) within this e-filed document.

ORDER

IT IS SO ORDERED.