STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE
Plaintiff, Meryl Borders-Humphrey, and Defendant, Prison Health Services, Inc., through their counsel, jointly stipulate to continuing the case management conference currently scheduled for Friday, July 25, 2008, for the following reasons:
Plaintiff's employment with defendant Prison Health Services, Inc. (PHS) was governed by a collective bargaining agreement. Plaintiff filed a union grievance challenging the termination of her employment. That grievance has now proceeded to arbitration. The arbitration commenced on December 4, 2007, a second session was held on January 17, 2008, and a third and final session on Wednesday, February 6, 2008. The parties submitted post-arbitration briefs and are now awaiting a decision from the assigned arbitrator. Because the resolution of the arbitration could impact the scope and timing of the present proceeding, the parties are not presently in a position to schedule this case for completion of discovery or trial.
For these reasons, the parties respectfully request that the July 25 case management conference be continued for approximately 30 days (August or early Sepetmeber 2008) in order to allow an opportunity to receive a ruling from the arbitrator.
McDONOUGH HOLLAND & ALLEN PC Attorneys at Law
LAURA J. FOWLER Attorneys for Defendant Prison Health Services, Inc.
LAW OFFICES OF MICHAEL C. COHEN
MICHAEL C. COHEN Attorneys for Plaintiff Meryl Borders-Humphrey
Having read the foregoing Stipulation and good cause appearing therefor,
IT IS SO ORDERED that the Case Management Conference is continued to September 5 ____________________, 2008.
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