JOINT STIPULATION AND ORDER FOR CONTINUANCE OF PRETRIAL
The parties to the above captioned litigation stipulate to and respectfully propose the following:
WHEREAS trial is currently set for June 8, 2010;
WHEREAS to allow for continued efforts to resolve this litigation, on December 23, 2009 the parties moved to continue the trial, (Dkt. 109 and 109.3), and on December 29, 2009 the Court entered an order continuing the trial until June 8, 2010 and the final pre-trial conference until March 15, 2010 and requiring the final joint pretrial statement to be filed seven days before the pre-trial conference (Dkt. 112);
WHEREAS the parties have engaged in lengthy settlement discussions and have reached a tentative settlement subject to management and client approval, but have not yet completed the formal management or client approval process;
WHEREAS the record snow storms in the Washington, D.C. area and resulting government closures have delayed the Federal defendants' work on the settlement documents and completion of the management review approval process;
WHEREAS the parties expect to complete the management review and approval process by the end of March, but the current pre-trial schedule would require the parties to cease work on settlement approval and prepare their joint pre-trial statement by March 8, 2010; and
WHEREAS accordingly, in an effort to conserve judicial time and resources, the parties jointly request that the Court continue the pretrial conference presently set for March 15, 2010 to April 12, 2010, during which time the parties expect to complete the parties' settlement approval processes; and
THEREFORE, the parties hereby stipulate as follows: The parties request that the Court continue the Final Pretrial Conference, currently scheduled for March 15, 2010, until April 12, 2010, or as soon thereafter as may be convenient for the Court.
The Final Pretrial Conference is rescheduled for April 12, 2010, at 2:30 p.m. A joint pretrial statement is to be filed seven days prior to the hearing.
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