STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING ON SECRETARY'S MOTION FOR CIVIL CONTEMPT

SUSAN ILLSTON, District Judge.

Petitioner Thomas E. Perez, Secretary of Labor, United States Department of Labor (the "Secretary") and Respondent RMRF Enterprises, Inc. ("RMRF") (together the "parties") hereby consent to the following Stipulation and entry of an Order from the Court in accordance herewith:

1. On December 20, 2013, the Secretary filed a motion for civil contempt against RMRF for its failure to comply with this Court's July 31, 2013 Order to produce documents responsive to the Secretary's administrative subpoena. The hearing on that motion is scheduled for April 4, 2014.

2. On February 24, 2014, RMRF produced approximately 224 pages of documents. The Secretary has been in the process of reviewing this material to determine whether it is responsive to the subpoena.

3. Following February 24, 2014, RMRF produced an additional 150 pages of documents. In response to a portion of the documents produced, the Secretary has asked for additional productions of various sets of documents, and RMRF and its counsel are currently determining whether such documents exist within the possession, custody, and control of RMRF or its principals.

4. In light of the fact that RMRF has retained counsel and produced documents, and additional documents are scheduled to be produced on March 31, 2014, the parties stipulate and respectfully request that the Court continue the hearing on the Secretary's motion for civil contempt by six weeks, to May 16, 2014, or to any time thereafter that is convenient for the Court. Continuing the hearing will allow the Secretary time to properly review all the documents that RMRF produced and will produce.

5. Continuing the contempt hearing will further conserve the resources of the parties and the Court in the event that RMRF makes a complete production in compliance with this Court July 31, 2013 Order, and thus moots the need for the Secretary's motion for contempt.

IT IS SO ORDERED.