SECOND JOINT STIPULATION TO EXTEND THE BRIEFING SCHEDULE FOR THE UNITED STATES' MOTION FOR SUMMARY JUDGMENT; [PROPOSED] ORDER

MIRANDA M. DU, District Judge.

COMES now Plaintiffs and Counterclaim Defendants Michael F. Reeder ("Reeder") and Pamela O'Keefe, as Trustee of the Jordan Grace Reeder Irrevocable Trust, dated April 15, 1993 ("JGR Trust") and the Darby Leigh Reeder Irrevocable Trust ("DLR Trust"), Defendant and Counterclaimant, United States of America ("United States"), by and through their undersigned counsel, and submit a joint stipulation to extend the briefing dates with respect to the Motion for Summary Judgment which was refiled by the United States of America ("United States") with this Court on April 15, 2019 [ECF 84].

The Motion for Summary Judgment was originally filed on May 1, 2018 [ECF 65]. Meanwhile, Plaintiffs and Counterclaim Defendants submitted a global settlement offer to the government. Formal consideration of the offer by the government was ongoing until approximately April 15, 2019. Upon the tentative rejection of the global settlement offer, the government refiled its Motion for Summary Judgment in accordance with the Court's Order of February 11, 2019 [ECF 81].

Plaintiff's counsel, together with Plaintiff, attended an in-person settlement conference with the supervisor whom has settlement authority in Washington D.C. on Thursday, May 16, 2019. The parties are optimistic that in principal a settlement has been reached, but there are still some terms to be determined including reaching a workable payment plan. The proposed settlement will result in a joint motion for stipulation to judgment resolving this action in its entirety. Accordingly, the parties are hopeful that it will be not be necessary to further brief the government's Motion for Summary Judgment.

Based on the foregoing, the parties respectfully request an additional 60-day extension to the briefing schedule. The parties stipulate that the current briefing schedule dates be extended with the Opposition by the Plaintiff and Counter Defendant to the United States' Motion for Summary Judgment to be filed by August 12, 2019, and the United States' Reply Brief to be filed by September 12, 2019. The Parties will immediately advise the Court when a full settlement is reached.

IT IS SO ORDERED.