UNOPPOSED MOTION TO STAY PROCEEDINGS PENDING COMPROMISE SETTLEMENT

NANCY J. KOPPE, Magistrate Judge.

The United States of America respectfully requests this Court enter a ninety (90) day stay of all proceedings and deadlines, including all motion and discovery deadlines, in order to allow the parties to complete the terms of a settlement agreement; allow for the exchange of payment pursuant to the settlement agreement; and thereafter to execute and enter a Stipulation to Dismiss.

In support of this motion the United States submits as follows:

1. On February 20, 2014, Plaintiff filed a complaint in Justice Court, Clark County, Nevada, which was removed to Federal District Court by the United States on March 18, 2014. The Court granted the United States' motion to extend time to answer until August 25, 2014, in order for parties to continue with discussions and to finalize a pending settlement agreement.

2. On August 20, 2014, the parties agreed to and signed a compromise settlement which will resolve all outstanding claims between the parties.

3. Plaintiff's attorney does not object to the requested stay of ninety (90) days.

4. The motion to stay is reasonable, made in good faith, and not made for purposes of delay. Granting this stay will permit the parties time to finalize the settlement agreement process which will result in a full dismissal of this action.

WHEREFORE, for the above reasons, the United States respectfully requests the instant Motion to Stay Proceedings for ninety (90) days be granted., until November 24, 2014.