STIPULATION AND [PROPOSED] ORDER TO STAY CLAIMS

SAUNDRA BROWN ARMSTRONG, District Judge.

Plaintiffs RESOURCE RENEWAL INSTITUTE, CENTER FOR BIOLOGICAL DIVERSITY, and WESTERN WATERSHEDS PROJECT, and Defendants NATIONAL PARK SERVICE, and CICELY MULDOON IN HER OFFICIAL CAPACITY AS SUPERINTENDENT OF POINT REYES NATIONAL SEASHORE (collectively, the "Parties"), through their undersigned counsel hereby jointly stipulate and respectfully request that the Court: (1) stay Claims Two and Three under the terms described below; and (2) order that, if and when stay is lifted, Defendants shall file an answer within 21 days of reinstatement or amendment of these Claims, whichever is later. The Parties jointly declare in support of these stipulated requests:

WHEREAS, the Court issued an Order on Friday, July 15, 2016, denying Defendants' Motion to Dismiss, and granting Defendants' Alternative Motion for a More Definite Statement, ECF No. 49;

WHEREAS, Plaintiffs intend to file a First Amended Complaint ("FAC") no later than August 5, 2016, pursuant to the Court's Order;

WHEREAS, Plaintiffs intend to file a Motion for Preliminary Injunctive Relief on August 12, 2016, under Claim One, and the Parties have stipulated to, and the Court has ordered, a briefing schedule for submission of the Motion as to Claims Two and Three, ECF No. 54;

WHEREAS, the Court issued an Order on July 22, 2016, stating the Court's intention to refer this action to a magistrate judge for a mandatory settlement conference to be scheduled on an expedited basis, and ordering the Parties to file a list of preferred magistrate judges by July 27, 2016;

WHEREAS, the Parties believe that staying Claims Two and Three will conserve judicial resources, save the Parties' time and expense, and would avoid proceedings on Claims Two and Three which may be unnecessary;

WHEREAS the Parties' Stipulated stay on Claims Two and Three will not alter the date of any existing deadline or event set by Court order, including the deadline for Defendants' production of the Administrative Records on July 29, 2016, and August 26, 2016, ECF No. 34;

NOW THEREFORE, the Parties through their respective attorneys stipulate and jointly request that the Court stay Claims Two and Three on the following terms:

1. The stay of Claims Two and Three shall go into effect on August 6, 2016, after Plaintiffs have filed a FAC to provide a more definite statement on Claims Two and Three, except that the entry of the stay shall not apply to or stay Defendants' production of the administrative record on Claims Two and Three, on the terms ordered by the Court, ECF No. 34, or any further proceedings as to the sufficiency of that record;

2. Nothing in this Stipulation shall have any effect on Claim One;

3. Plaintiffs, in their sole discretion, but after notice to, and meeting and conferring with, Defendants, may (1) seek leave to lift the stay and reinstate either or both of Claims Two and Three, and if necessary, (2) seek leave to further amend or supplement the FAC if the ranching authorizations identified in the FAC have been superseded; and,

4. In the event the stay is lifted, Defendants shall file an Answer within 21 days of (1) an order reinstating Claims Two and Three, or (2) the filing of a Supplemental and/or Amended complaint other than the FAC, as set forth in Paragraph 3, whichever is later.

SO STIPULATED AND AGREED.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.