STIPULATION TO CONTINUE HEARING; [PROPOSED] ORDER

KANDIS A. WESTMORE, Magistrate Judge.

Plaintiffs Our Children's Earth Foundation and Ecological Rights Foundation ("Plaintiffs"), and Defendants U.S. Environmental Protection Agency and Gina McCarthy, Administrator, U.S. Environmental Protection Agency ("Defendants") hereby stipulate and respectfully request a Court order continuing the hearing on Plaintiffs' motion for attorneys' fees and costs currently scheduled for September 3, 2015.

WHEREAS, on February 26, 2015, Plaintiffs filed Motion for Attorneys' Fees and Costs, Dkt. # 59, and that motion has been fully briefed;

WHEREAS, on May 20, 2015, the Court continued the motion hearing on Plaintiffs' motion to September 3, 2015, Dkt. # 70;

WHEREAS, undersigned counsel for federal Defendants underwent an unexpected medical procedure on September 2, 2015, and has been instructed not to travel;

WHEREAS, undersigned counsel for federal Defendants must undergo another medical procedure in the near future, but that procedure has not yet been scheduled;

WHEREAS, undersigned counsel for federal Defendants represents that he requires a continuation of the motions hearing to recover from these medical procedures before he is able to travel for this hearing;

NOW THEREFORE, the parties respectfully request that the Court enter the attached order providing Defendants until September 11, 2015 to file a stipulation providing the Court with a list of potential dates to continue the hearing for Plaintiffs' Motion for Attorneys' Fees and Costs, Dkt. # 59.

[PROPOSED] ORDER

The above STIPULATION TO CONTINUE HEARING is GRANTED. The parties shall have until September 11, 2015 to file a stipulation providing a list of potential dates to continue the hearing on Plaintiffs' Motion for Attorneys' Fees and Costs, Dkt. # 59.