STIPULATION TO STAY PROCEEDINGS AND CONTINUE HEARING; [PROPOSED] ORDER

JEFFREY S. WHITE, District Judge.

Plaintiffs Our Children's Earth Foundation and Ecological Rights Foundation ("Plaintiffs") and the Defendants in the above captioned matter (collectively, the "Parties") hereby stipulate and respectfully request of the Court an order staying all proceedings until August 18, 2014.

WHEREAS, on February 6, 2014, the Parties participated in Court-designated mediation that resulted in an agreement in principle, subject to approval by the appropriate individuals at U.S. Environmental Protection Agency and Department of Justice;

WHEREAS, the Parties have reduced their tentative agreement into a proposed consent decree;

WHEREAS, additional time is needed to acquired the necessary approvals for the consent decree from the Department of Justice;

WHEREAS, Defendants have a pending partial motion to dismiss set for hearing on July 11, 2014;

WHEREAS, a stay would serve judicial economy and the resources of the Parties and the Court by potentially allowing for resolution of this case without litigation.

NOW THEREFORE, the parties respectfully request that the Court enter an order staying all proceedings until August 18, 2014 and continuing the hearing for the motion to dismiss to a later date.

[PROPOSED] ORDER

The above STIPULATION TO STAY PROCEEDINGS is GRANTED. All proceedings shall be stayed until August 18, 2014. The hearing for the pending motion to dismiss is continued to September 5, 2014.