STIPULATION EXTENDING TIME TO ANSWER OR OTHERWISE RESPOND AND [PROPOSED] ORDER

KANDIS A. WESTMORE, District Judge.

IT IS HEREBY STIPULATED by and between Defendant the United States of America ("United States"), and Plaintiff Donald E. Morris ("Plaintiff") by and through undersigned counsel and pursuant to Fed. R. Civ. P. 16(b)(4) and Local Civil Rule 6-2, that good cause exists and the parties request that the Court continue the date for the United States to answer or otherwise respond to Plaintiff's Complaint, and the United States states as follows in support:

Plaintiffs commenced the instant action on or about January 27, 2016. Upon learning of the Complaint, the Department of Justice contacted the Internal Revenue Service's Office of Chief Counsel and requested the administrative file associated with this case. The Office of Chief Counsel has yet to provide a copy of the administrative file to the Department of Justice. Without the administrative file, counsel for the United States is unable to prepare an adequate response to the Complaint.

Accordingly, the parties hereby stipulate that the United States shall have until May 31, 2016, to answer or otherwise respond to Plaintiff's Complaint. The requested extension is not being made for purposes of delay, but to allow for a review of the relevant administrative materials. No party has obtained any previous extensions in this matter.

[PROPOSED] ORDER

Upon stipulation of the parties, and for good cause shown, it is hereby ORDERED that the United States of America shall have until May 31, 2016, to answer or otherwise respond to Plaintiff's Complaint.

SO ORDERED.