BASIS FOR REQUEST FOR EXTENSION

Counsel for the Defendant has indicated a willingness to discuss settlement

of this matter. Time is needed for the parties to discuss the possible resolution of

this matter. Defendant has specifically requested that Plaintiff seek the extension

requested herein so that, among other things, the parties may discuss settlement. If

a resolution can be reached in this matter, most likely such a resolution would be a

global resolution that would resolve this case in its entirety as to all the parties.

With the above in mind, Plaintiff seeks an extension of time for Defendant

to respond to the Complaint not for delay, but to permit the parties an opportunity

to resolve Plaintiff’s claims without the need for further litigation. .....