JOINT STIPULATION AND [PROPOSED] ORDER TO VACATE BRIEFING SCHEDULE AND STAY PROCEEDINGS TO ALLOW TIME TO NEGOTIATE RESOLUTION OF PLAINTIFF's REQUEST FOR ATTORNEY'S FEES AND COSTS

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. On August 2, 2015, Plaintiff filed an Amended Complaint for Declaratory and Injunctive Relief under the Freedom of Information Act ("FOIA") that identifies 12 FOIA Requests that are the subject of this litigation ("Complaint"). Dkt. No. 8.

2. Defendant has completed its production of documents responsive to the 12 FOIA Requests that are the subject of this litigation, to the extent such documents exist.

3. On October 1, 2015, pursuant to stipulation by the parties, this Court stayed this action and continued the Case Management Conference originally scheduled for November 10, to December 16, 2015. Dkt. No. 19.

4. On December 1, 2015, this Court issued an Order pursuant to the Initial Case Management Statement filed by the parties continuing the Case Management Conference scheduled for December 16, 2015 to February 10, 2016, and continuing the stay of this action until February 10, 2016. Dkt. No. 21.

5. On February 10, 2016, this Court issued a Scheduling Order requiring the parties to file dispositive motions by May 27, 2016, and setting trial for September 12, 2016. Dkt. No. 25.

6. On April 19, 2016, pursuant to the request of the parties (Dkt. No. 28), this Court modified the case deadlines by issuing a Scheduling Order that set out a briefing schedule for the parties' anticipated cross-motions for summary judgment. Dkt. No. 30.

7. After an extensive meet and confer process, Plaintiff has decided not to further challenge the sufficiency of Defendant's search for responsive documents, or Defendant's redactions and withholdings pursuant to certain FOIA statutory exemptions.

8. Accordingly, as no further issues exist between the parties that would require this Court to consider and rule on cross-motions for summary judgment, the parties stipulate and request that this Court vacate the briefing schedule set out in this Court's April 19, 2016 Scheduling Order, set a Case Management Conference for July 20, 2016 at 2:00 pm, and stay the case until July 20, 2016 to allow time for the parties to negotiate a resolution of the only remaining issue in this matter regarding Plaintiff's request for attorney's fees and costs. The parties will submit a Joint Supplemental Case Management Statement seven (7) days before the Case Management Conference.

IT IS SO STIPULATED.

IT IS SO ORDERED.