STIPULATUION AND ORDER REQUESTING BINDING ARBITRATION ON ONLY THE ISSUE OF PLAINTIFFS' ATTORENYS' FEES, LITIGATION EXPENSES AND COSTS BEFORE NEUTRAL ARBITER JUSTICE JAMES R. LAMBDEN

HAYWOOD S. GILLIAM, JR., District Judge.

After engaging in a Settlement Conference on March 14, 2018, and subsequent settlement phone conferences with Magistrate Judge Robert M. Illman, Plaintiffs ODIS MARTIN and LORETHA MARTIN ("Plaintiffs") and Defendants SERVICE HOSPITALITY, LLC, dba CLARION HOTEL CONCORD; CHOICE HOTELS INTERNATIONAL, INC.; LEISURE HOTEL GROUP, LLC ("Defendants"), by and through their respective counsel of record, hereby jointly stipulate and request that the Court order the parties to resolve the remaining issue of attorney fees, litigation expenses, and costs at binding arbitration for the following good cause and upon the following conditions:

1. The Parties have agreed and signed two Court Enforceable Settlement Agreements, one regarding injunctive relief, the other regarding damages;

2. To resolve this case in total and with finality, the parties have agreed to request that the Court order binding arbitration before Justice James R. Lambden, and that he act as neutral and binding arbiter of the remaining issues of attorney fees, litigation expenses and costs. The parties' agreement to submit to binding arbitration is premised on the conditions that:

a. The decision by Justice Lambden will be adopted as an order by this Court;

b. No party will dispute the decision, or appeal it in any way;

c. For purposes of briefing the attorney fees, litigation, expenses and costs issue only, Defendants will stipulate that Plaintiffs are the prevailing parties in this case;

d. Justice Lambden shall hold a hearing on the matter on or before May 3, 2018 (45 days from March 19, 2018), subject to this date being convenient for his schedule;

e. 30 days after Justice Lambden issues his decision, Defendant shall pay the damages as previously agreed plus any and all attorney fees, litigation expenses and costs awarded by the decision;

f. Plaintiff shall file the Arbiter's decision and both Court Enforceable Settlement Agreements at the same time for this Court to issue Orders on each, bringing this matter to a close.

IT IS SO STIPULATED.

FILER'S ATTESTATION

Pursuant to Local Rule 5-1, I hereby attest that I, Paul L. Rein, attorney with thee Law Offices of Paul Rein, received the concurrences of Martin Orlick and Laura Ryan in the filing of this document.

ORDEER

Pursuant to the stipulation of the parties, and for good cause shown, IT IS SO ORDERED.