STIPULATED MOTION AND [PROPOSED] ORDER EXTENDING TIME FOR RESPONSIVE PLEADING

ROBERT S. LASNIK, District Judge.

Pursuant to the order entered by this Court on the stipulation between Plaintiff MAPLE LEAF HOUSING, INVESTMENTS, LLC's ("Plaintiff") and Defendant TEXACO DOWNSTREAM PROPERTIES INC. ("Defendant"), Defendant's responsive pleading is due March 1, 2019. See, Dkt. # 24. Plaintiff and Defendant now jointly move under FRCP 6(b) for further a 21-day extension of Defendant's deadline to file a responsive pleading to March 22, 2019. There is good cause for granting an extension because Plaintiff and Defendant have reached agreement, in principal, to resolve issues raised in Defendant's November 30, 2018, meet and confer correspondence ("Meet and Confer Correspondence") such that there will be no need for a motion to dismiss certain claims. Additionally, the parties have further agreed, subject to the Court's approval, to stay for 120 days all litigation deadlines and activities while an environmental investigation is jointly undertaken at Plaintiff's property. Based on the foregoing, Plaintiff drafted and circulated (1) an agreement that, among other things, resolves issues raised in the Meet and Confer Correspondence and allows the parties to undertake the environmental investigation of Plaintiff's property (the "Agreement"), and (2) a stipulated order staying all litigation deadlines and activities for 120 days while the environmental investigation is undertaken and that also proposes new case management deadlines upon the expiration of the 120 day stay period (the "Stay"). Defendant recently provided its comments and revisions on the Agreement and Stay to Plaintiff. The parties have not yet finalized these documents.

The parties jointly request an further 21-day extension of Defendant's deadline to file a responsive pleading to allow the parties to: (1) finalize the Agreement, and (2) finalize and present to this Court the Stay.

Pursuant to FRCP Rule 6(b), the Court may, for good cause, extend the time for Defendant to respond to Plaintiff's Complaint.

Based on the foregoing, Plaintiff and Defendant jointly request that the Court issue an order extending the deadlines for Defendant's responsive pleading twenty-one days to March 22, 2019.

IT IS SO STIPULATED THROUGH COUNSEL OF RECORD

I attest that concurrence in the filing of this document has been obtained from David F. Stearns, counsel for Maple Leaf Housing Investments, LLC.

[PROPOSED] ORDER

The deadlines in this case are hereby extended as follows:

Defendant's responsive pleading shall be filed no later than March 22, 2019.

PURSUANT TO STIPULATION, IT IS SO ORDERED.