PARTIES' STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE TO FILE MOTION FOR ATTORNEYS' FEES AND TO CONTINUE CASE MANAGEMENT CONFERENCE

RICHARD SEEBORG, District Judge.

Pursuant to Local Rule 54-5 (a), Plaintiffs Committee for a Better Arvin et al. and Defendants Andrew Wheeler et al. ("EPA"), stipulate to extend the time for Plaintiffs to file a motion for attorneys' fees from January 7, 2019, by 60 days, to March 8, 2019, so that they may continue settlement discussions. The parties also stipulate to continue the case management conference scheduled on January 24, 2019, by 77 days, to April 11, 2019.

In support of this stipulation, the parties state as follows:

WHEREAS, on October 24, 2018, this Court entered an order granting Plaintiffs' motion for summary judgment (Dkt. 22);

WHEREAS, the Court's order specified that "[p]ursuant to 42 U.S.C. § 7604(d), defendants shall reimburse plaintiffs for the reasonable costs plaintiffs have incurred as a result of this litigation, including reasonable attorney fees, in an amount to be determined upon submission of the necessary application in accordance with the rules;"

WHEREAS, Civil Local Rule 54-5(a) provides that motions for attorneys' fees must be filed within 14 days of entry of judgment unless stipulated otherwise by the parties and ordered by the Court;

WHEREAS, on October 31, 2018, the parties stipulated to extend the deadline for Plaintiffs to file a motion for attorneys' fees and costs to January 7, 2019 (Dkt. 23) and the Court ordered such an extension on November 1, 2018 (Dkt. 24);

WHEREAS, Plaintiffs and EPA have since conferred so they may assess potential agreement on Plaintiffs' claim for attorneys' fees, and continue to confer productively about a potential agreement to resolve attorneys' fees;

NOW, THEREFORE, the parties, by and through their counsel, stipulate and agree, and request that the Court enter an order extending the deadline for Plaintiffs to file a motion for attorneys' fees and costs to March 8, 2019. Further, the parties request that the Court enter an order continuing the case management conference scheduled on January 24, 2019 until April 11, 2019. By entering into this stipulation, EPA does not waive any defenses as to attorneys' fees or costs.

Pursuant to the stipulation of the parties, IT IS SO ORDERED.