JOINT STIPULATION TO FURTHER EXTEND DEADLINE TO FILE MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT AND HEARING ON MOTION FOR PRELIMINARY APPROVAL; [PROPOSED] ORDER,

RICHARD SEEBORG, Magistrate Judge.

Plaintiff VALERIE CASHON ("Plaintiff") and Defendants KINDRED HEALTHCARE OPERATING, INC. and GENTIVA CERTIFIED HEALTHCARE CORP. ("Defendants") (collectively, the "Parties"), through their respective counsel, hereby stipulate, subject to Court approval, as follows.

WHEREAS, on November 19, 2017 the parties participated in mediation in this action;

WHEREAS, on November 28, 2017, Plaintiff filed a Notice of Proposed Class Settlement and Request for Preliminary Approval Hearing Date [Dkt No. 58] in which Plaintiff informed the court of a proposed settlement and sought a motion for preliminary approval of class action settlement hearing date in late January 2018;

WHEREAS, on November 28, 2017, the Court issued an Order Staying Currently Set Date and Setting Schedule for Preliminary Approval [Dkt No. 59] in which the Court ordered the parties to file the motion for preliminary approval by January 11, 2018 and set the hearing regarding preliminary approval on February 1, 2018 at 1:30 p.m. in Courtroom 3;

WHEREAS, the Parties have previously requested and the Court approved the Parties' request to move the deadline to file the motion for preliminary approval [Dkt Nos. 61-64];

WHEREAS, the current deadline for Plaintiff to file her motion for preliminary approval is March 1, 2018;

WHEREAS, the Parties have been and continue to work diligently to prepare the long-form stipulation regarding class settlement but have not yet finalized that agreement;

WHEREAS, the parties need further additional time to finalize that agreement after which the motion for preliminary approval can be filed and heard;

WHEREAS, the parties believe that it would be most efficient for the parties and the Court to continue the deadline regarding motion for preliminary approval;

NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED, subject to Court approval, as follows:

1. The deadline for Plaintiff to file her motion for preliminary approval currently scheduled for March 1, 2018 shall be continued to March 6, 2018; and

2. The hearing on Plaintiff's motion for preliminary approval currently scheduled for March 29, 2018 remain on that date or the Court's earliest available hearing date thereafter.

IT IS SO STIPULATED.

[PROPOSED] ORDER

Having considered the Parties' Joint Stipulation to Further Extend Deadline to File Motion for Preliminary Approval of Class Action Settlement and Hearing on Motion for Preliminary Approval, and good cause appearing therefor, the Court hereby orders as follows:

1. The deadline for Plaintiff to file her motion for preliminary approval is hereby continued from March 1, 2018 to, 2018; March 6

2. The hearing on Plaintiff's motion for preliminary approval shall be set on March 29, 2018 at ________. 1:30 pm

IT IS SO ORDERED.