STIPULATED MOTION FOR STAY; [PROPOSED] ORDER

EDWARD M. CHEN, District Judge.

Pursuant to Civil L.R. 6-2, Basel Action Network ("BAN"), Sierra Club, and Center for Biological Diversity (collectively "Plaintiffs") and Defendant United States Environmental Protection Agency ("EPA") and Lisa P. Jackson, Administrator, U.S. EPA, in her official capacity (collectively "Defendants"), hereby stipulate to and request an order staying the above-captioned litigation pursuant to the terms of the attached Joint Stipulation for Stay of All Proceedings (Exhibit A). The parties have agreed to the terms of a stay to allow Defendants to respond to the outstanding requests in Plaintiffs' petitions under the Marine Protection, Research, and Sanctuaries Act ("MPRSA"), which are currently pending with EPA. The parties' negotiations during the course of the stay and/or EPA's response to the MPRSA portions of Plaintiffs' petitions may obviate the need for further litigation. Alternatively, if the parties are unable to reach agreement, Plaintiffs anticipate seeking leave to amend the complaint upon expiration of the stay to add claims under the MPRSA. Because there is significant overlap in the factual basis for Plaintiffs' TSCA and MPRSA claims, litigating these claims together promotes judicial economy.

In support of this stipulated motion, the parties submit the Declaration of Leslie M. Hill, counsel of record for Defendants (attached as Exhibit B).

[PROPOSED] ORDER

Pursuant to Stipulation, IT IS SO ORDERED.