SECOND STIPULATION AND ORDER FOR EXTENSION OF TIME FOR MARIA GUADALUPE HEIM dba SHELL aka MEXICALI MARKET; STEPHEN J. HEIM dba SHELL aka MEXICALI MARKET; NAM HUU NGUYEN, Successor Trustee of THE DANG-NGUYEN FAMILY REVOCABLE LIVING TRUST 2005; NGA THI DANG, Successor Trustee of THE DANG-NGUYEN FAMILY REVOCABLE LIVING TRUST 2005 TO RESPOND TO COMPLAINT

BARBARA A. MCAULIFFE, Magistrate Judge.

WHEREAS:

1. Plaintiff RONALD MOORE filed this action on November 24, 2014.

2. This is the second request for an extension of time for MARIA GUADALUPE HEIM dba SHELL aka MEXICALI MARKET; STEPHEN J. HEIM dba SHELL aka MEXICALI MARKET; NAM HUU NGUYEN, Successor Trustee of THE DANG-NGUYEN FAMILY REVOCABLE LIVING TRUST 2005; and NGA THI DANG, Successor Trustee of THE DANG-NGUYEN FAMILY REVOCABLE LIVING TRUST 2005 ("Defendants"). A previous extension of time was granted by the plaintiff within the statutory allowance; thus, court approval is required for a further extension of time.

3. Plaintiff and Defendants are in settlement negotiations at this time.

4. Defendants have presented a proposed plan of remediation, and time is needed for the parties to review, make any needed adjustments and prepare a proposed settlement agreement.

5. The parties agree that settlement of this case would save valuable court time and resources.

6. The parties have agreed to extend Defendant's time to respond to the complaint until February 19, 2015, subject to the court's approval, and believe that the case can be settled within that time.

7. This extension of time will not alter any date or event already set by Court order, including the mandatory scheduling conference.

NOW THEREFORE, Defendants through their attorneys, and Plaintiff Ronald Moore, through his attorneys, hereby stipulate and agree that the time for Defendants MARIA GUADALUPE HEIM dba SHELL aka MEXICALI MARKET; STEPHEN J. HEIM dba SHELL aka MEXICALI MARKET; NAM HUU NGUYEN, Successor Trustee of THE DANG-NGUYEN FAMILY REVOCABLE LIVING TRUST 2005; and NGA THI DANG, Successor Trustee of THE DANG-NGUYEN FAMILY REVOCABLE LIVING TRUST 2005 to answer or otherwise respond to the Complaint shall be extended up to and including February 19, 2015, pending court approval.

IT IS SO STIPULATED.

IT IS SO ORDERED.