JOINT STIPULATION AND [PROPOSED] ORDER TO STAY PROCEEDINGS

JON S. TIGAR, District Judge.

Pursuant to Local Rule 6-2(a), Plaintiff Alan Stein ("Plaintiff") and Defendant United States Department of Commerce ("Defendant") hereby stipulate and agree, subject to the approval of the Court, that:

1. Plaintiff's Complaint identifies 12 FOIA Requests that are the subject of this litigation.

2. Defendant has completed its response with respect to Plaintiff's FOIA Requests bearing the tracking numbers: DOC-NOAA-2015-000597, DOC-NOAA-2015-000693; DOC-NOAA-2015-000694; DOC-OIG-2015-000716 and DOC-OIG-2015-000753. Plaintiff will determine if he believes there are any remaining issues with such responses and will meet and confer with Defendant regarding same.

3. Based on the information available to date, Defendant will make its best efforts to complete its response to Plaintiff's FOIA Requests bearing the tracking numbers DOC-NOAA-2015-000595, DOC-NOAA-2015-000596, DOC-NOAA-2015-000 606 and DOC-NOAA-2015-000747 by October 22, 2015.

4. Based on the information available to date, Defendant intends to determine by October 22, 2015 if it has documents responsive to Plaintiff's FOIA request bearing the tracking number DOC-NOAA-2015-000144, after which time, if applicable, Defendant will provide a release date for such documents.

5. Based on the information available to date, Defendant will make its best efforts to make an initial production in response to Plaintiff's FOIA Request bearing the tracking number DOC-NOAA-2013-000138, likely to be followed by additional rolling productions at a later date, and to complete its response to Plaintiff's FOIA Request bearing the tracking number DOC-NOAA-2013-000139 by November 23, 2015.

6. For any response to Plaintiff's FOIA Requests for which Defendant has not completed its response by November 23, 2015, Defendant shall release responsive documents in a phased process as expeditiously as possible as Defendant completes its review, and that the parties anticipate the rate of release will approximate 2,500 pages every four weeks thereafter until the process is complete.

7. The parties stipulate and request that the Case Management Conference currently scheduled for November 10, 2015 be continued to December 15, 2015 or any date thereafter that is convenient for the Court, with a Case Management Statement to be filed seven days before the continued Case Management Conference.

8. To allow time for Defendant to complete its responses to Plaintiff's FOIA Requests as stated above and for the parties to resolve as many issues in this matter as possible between themselves, the parties stipulate and request that this matter be stayed through the date of the continued Case Management Conference.

9. The deadline for Defendant's response to Plaintiff's Complaint, which by earlier stipulation between the parties was extended to October 5, 2015, shall also be stayed, and the parties further agree and stipulate that they will confer and propose to the Court a schedule for Defendant's response to either Plaintiff's Complaint or any Amended Complaint that Plaintiff seeks leave to file.

IT IS SO STIPULATED.

[PROPOSED] ORDER

Pursuant to the stipulation by the parties, and good cause having been shown, it is hereby ordered that this matter is stayed, including Defendant's response to Plaintiff's Complaint. The Case Management Conference originally scheduled for November 10, 2015 is continued to December 16, 2015 at 2:00 PM. The parties shall file a Case Management Statement on or before December 2, 2015. This matter shall be stayed until the date of the Case Management Conference.

It is further ordered that for any response to Plaintiff's FOIA Requests for which Defendant has not completed its response by November 23, 2015, Defendant shall continue to release all documents responsive to Plaintiff `s FOIA request in a phased process as expeditiously as possible as Defendant completes its review at a rate of release no less than 2,500 pages every four weeks thereafter until the process is complete.

IT IS SO ORDERED.