JOINT CASE MANAGEMENT CONFERENCE STATEMENT AND STIPULATION TO CONTINUE JUNE 4, 2014 CASE MANAGEMENT CONFERENCE TO AUGUST 6, 2014; ORDER THEREON

CLAUDIA A. WILKEN, District Judge.

WHEREAS, the parties reached a settlement in principal of this matter following mediation with Judge Warren (Ret.) on November 5, 2013;

WHEREAS the parties have been exchanging drafts of the requisite settlement agreements and negotiating numerous terms of same;

WHEREAS, due to the complexity of the issues, the number of parties involved, and the number of law firms representing various parties, the parties have not yet found final language for the settlement agreements acceptable to all parties;

WHEREAS, over the past 6 months, the parties have repeatedly engaged Judge Warren (Ret.) for his assistance in finalizing the terms of the settlement;

WHEREAS, on May 22, 2014, the parties, including counsel for Chartis Specialty Insurance Company in the related insurance action, participated in a nine-hour mediation session before the Hon. James L. Warren (Ret.), to address the final terms of the settlement agreements;

WHEREAS, significant progress toward final resolution was made at the further mediation and the parties are still working to resolve some limited final terms and language in the settlement;

WHEREAS the parties believe that a further two month extension of the CMC will facilitate finalization of the settlement and allow them to work through the remaining drafting issues with oversight by Judge Warren (Ret.) on an as needed basis, and allow all parties and the Court to avoid unnecessary expenses and prevent wasting of judicial resources.

IT IS HEREBY STIPULATED by and between the parties through their designated counsel that the June 4, 2014 CMC be continued to August 6, 2014 at 2:00 P.M. or as soon thereafter as is convenient for the Court, and that the parties will submit a Joint Case Management Statement or individual Case Management Statements at least seven days before that date.

The undersigned have given authority to Marcie K. Farano to file this Stipulation and [Proposed] Order on their behalf.

ORDER

Pursuant to Stipulation, it is ordered that the June 4, 2014 CMC in the above captioned matter be continued to August 6, 2014 at 2:00 P.M. The parties must submit a Joint Case Management Statement or individual Case Management Statements at least seven days before that date.