STIPULATION AND ORDER TO EXTEND DEADLINES

SECOND REQUEST

CARL W. HOFFMAN, Magistrate Judge.

IT IS HEREBY STIPULATED by the parties hereto, by and through their undersigned counsel of record that, pursuant to LR 26-4, the amended Scheduling Order dated October 17, 2016 (Doc. # 22) be amended as follows:

I. Case Status

Mediation between Plaintiff and Defendant HARTFORD is currently scheduled for January 24, 2017. The current scheduling deadlines regarding Plaintiff's first cause of action against Hartford will remain in force. Following the filing of the October 17, 2016 Scheduling Order, Plaintiff and Defendant UNIVERSAL HEALTH SERVICES, INC. (UHS) entered into settlement discussions. On October 27, 2016, Plaintiff presented a demand to UHS. Defendant UHS is currently considering Plaintiff's demand, but requires additional time for its consideration due to unforeseen delays.

II. Reason for Request for Extension

Plaintiff's dispositive motion regarding her second cause of action against Defendant UHS is currently due by December 2, 2016. Plaintiff and UHS are currently attempting to resolve this claim and therefore propose that all briefing deadlines be extended into the new year.

III. Proposed Discovery Schedule regarding Plaintiff's second cause of action against UHS only:

Plaintiff CORBOSIERO and Defendant UHS propose an approximately 5-week extension of their remaining deadlines (Doc #22, ¶ III. B):

We, the undersigned, represent to the Court that this request for extension is made in good faith and not for purposes of delay.

WHEREFORE, the parties jointly request that this Court adopt the proposed scheduling as indicated above.

IT IS SO ORDERED.