STIPULATION AND [PROPOSED] ORDER EXTENDING DEADLINE FOR DEFENDANT FLUOR CORPORATION TO RESPOND TO FOURTH AMENDED COMPLAINT

MARIA-ELENA JAMES, Magistrate Judge.

Pursuant to Civil Local Rule 6-2(a), Plaintiff Northern California River Watch ("NCRW"), and Defendant Fluor Corporation ("Fluor"), hereby stipulate to extend the deadline by which Fluor must respond to the Fourth Amended Complaint by thirty (30) days, and jointly request that the Court enter the Proposed Order below. NCRW filed its Fourth Amended Complaint on June 24, 2013, and thus Fluor's current deadline to respond (including the three days added for electronic service) under Fed. R. Civ. Proc. 15(a)(3) and 6(d) is July 11, 2013. Under this Stipulation, Fluor's response to the Fourth Amended Complaint would be due no later than August 12, 2013.

The parties are jointly requesting this extension of time for Fluor to respond to the Fourth Amended Complaint because they have decided to initiate settlement negotiations, and would like to focus their efforts on attempting to settle the case rather than preparing responsive pleadings. The requested extension will not alter the date of any event or any deadline already fixed by any Court order. This is the first request for an extension of time for Fluor to respond to the Fourth Amended Complaint. And this requested extension will not affect the case schedule, given that the Court has not yet set a trial date or any discovery or motion cut-offs.

I declare under penalty of perjury that the foregoing is true and correct. I also attest, pursuant to Civil Local Rule 5-1(i)(3), that I have obtained concurrence in the filing of this Stipulation and Proposed Order from Jack Silver, counsel for NCRW.

PROPOSED ORDER

Having considered the foregoing Stipulation, and good cause appearing therefor, the Court hereby Orders that Fluor's response to the Fourth Amended Complaint shall be filed no later than August 12, 2013.

IT IS SO ORDERED.