STIPULATION AND [PROPOSED] ORDER TO STAY AND PROPOSED BRIEFING SCHEDULE

ANDREW P. GORDON, District Judge.

IT IS HEREBY STIPULATED AND AGREED BETWEEN Plaintiffs DANIEL SMALL, CAROLYN SMALL, WILLIAM CURTIN, DAVID COHEN, LANETTE LAWRENCE, and LOUISE COLLARD, and Defendants UNIVERSITY MEDICAL CENTER OF SOUTHERN NEVADA and JOHN ESPINOZA (collectively referred to as "the Parties") by and through their respective counsel, as follows:

On October 30, 2018, the Court granted the Parties' Stipulation to Extend Briefing Schedule regarding the Parties' Responses to the pending Motions for Summary Judgment. (ECF No. 346). Pursuant to such, the deadline to file Responses was extended to December 4, 2018. (Id.)

On November 5, 2018, Magistrate Leen granted Plaintiffs' Revised Application for Costs and Attorneys' Fees. (ECF No. 347). Pursuant to such, Magistrate Leen ordered UMC to pay Plaintiffs' attorneys' fees and costs by December 5, 2018. (Id.) The deadline to file an Objection to the Order granting Plaintiffs' Revised Application for Costs and Attorneys' Fees is November 19, 2018.

The Parties are engaged in settlement negotiations. To facilitate continued settlement negotiations, the Parties hereby stipulate and agree that this matter be stayed for all purposes for sixty (60) days.

The Parties further stipulate and agree that upon the expiration of sixty (60) days, the Parties' shall have twenty-one (21) days to file Responses to the pending Motions for Summary Judgment.

The Parties further stipulate and agree that UMC shall have until December 3, 2018, to file an Objection to the Order granting Plaintiffs' Revised Application for Costs and Attorneys' Fees. (ECF No. 347). Plaintiffs shall have fourteen (14) days upon the expiration of the sixty (60) day stay to file a response to UMC's Objection to the Order granting Plaintiffs' Revised Application for Costs and Attorneys' Fees.

Counsel for the Parties have met and conferred regarding an agreed stay; met and conferred regarding an extension of the briefing schedule for the Parties' Responses; and, met and conferred regarding an extension of the deadline to file an Objection to the Magistrate's Order granting Plaintiffs' Revised Application for Costs and Attorneys' Fees.

THEREFORE, the Parties hereby respectfully stipulate and request:

1. That this matter be stayed sixty (60) days for all purposes.

2. That upon the expiration of sixty (60) days, the Parties' shall have twenty-one (21) days to file Responses to the pending Motions for Summary Judgment.

3. That UMC shall have an extension to December 3, 2018, to file an Objection to the Order granting Plaintiffs' Revised Application for Costs and Attorneys' Fees.

4. Plaintiffs shall have fourteen (14) days upon the expiration of sixty (60) day stay to file a response to UMC's Objection to the Order granting Plaintiffs' Revised Application for Costs and Attorneys' Fees.

IT IS SO STIPULATED.

IT IS SO ORDERED.