Babarovich v. Standard Guaranty Insurance Company

IN THE UNITED STATES DISTRICT COURT 7 FOR THE WESTERN DISTRICT OF WASHINGTON AT SEATTLE 8 JOHN BABAROVICH, NO. C19-1395 RSM 9 Plaintiff, STIPULATED MOTION AND AGREED 10 vs. ORDER TO EXTEND CASE DEADLINES 11 STANDARD GUARANTY INSURANCE COMPANY, a Delaware Corporation, Defendant.

STIPULATION COMES NOW Plaintiff John Babarovich (“Babarovich”) and Defendant Standard Guaranty Insurance Company (“SGIC”) (collectively, the “Parties”), by and through their counsel of record and, pursuant to FRCP 26, LCR 7(d)(1) and 10(g), and the Court’s September 4, 2019 Order Regarding Initial Disclosures, Joint Status Report, and Early Settlement (Dkt. 5), file this Joint Motion to extend the case scheduling deadlines set by the Court by 45 days, as follows: 1. FRCP 26(f) Conference November 12, 2019 2. Initial Disclosures November 18, 2019 3. Joint Status Report and Discovery Plan November 25, 2019 24 STIPULATED MOTION AND AGREED ORDER - Page 1 eS INSLEE BES r 25 10900 NE 4th Sueet, Sul 1500 1_ | This is the first request by the Parties to extend these deadlines.

2 In support of the Joint Motion, the Parties show the Court as follows: 3 On September 27, 2019, counsel for SGIC emailed counsel for Babarovich in order to | arrange a time to conduct the FRCP 26(f) conference. Counsel for Babarovich, Gregory, Ursich, | advised he was unable to meet by the Court’s original October 2, 2019 deadline due to deposition | and trial preparation obligations. Mr. Ursich has, to date, been unable to meet with counsel for | SGIC due to time significant time constraints from his existing and pending trials, including a | trial commencing on Monday, October 21, 2019. Counsel for SGIC is agreeable to an extension | of the case deadlines in order to permit additional time for Mr. Ursich to complete his existing | and pending trials and for the Parties to meaningfully meet and confer in order to set a schedule | for the prompt completion of the case.

12 THEREFORE, the Parties jointly move the Court for an Order extending the FRCP 26(f) 13 conference to November 12, 2019, the Initial Disclosure deadline to November 18, 2019 and the | Joint Status Report and Discovery Plan deadline to November 25, 2019. Attached is a proposed | Order granting the Joint Motion.

16 | INSLEE BEST DOEZIE & RYDER, P.S. COZEN O’ CONNOR Gregory L. Ursich WSBA #18614 Kevin A. Michael WSBA #36976 | Attorney for Plaintiff John Babarovich Attorney for Defendant Standard Guaranty Insurance Company DATED onthis__ day of October, 2019 DATED on this __ day of October, 2019 24 STIPULATED MOTION AND AGREED ORDER - Page 2 INSL = BEST oe 1 Il. AGREED ORDER 2 IT IS, based on the above stipulation of counsel for all Parties, hereby ORDERED that the pending deadlines are extended as follows: 4 1. FRCP 26(f) Conference November 12, 2019 5 2. Initial Disclosures November 18, 2019 6 3. Joint Status Report and Discovery Plan November 25, 2019 7 IT IS SO ORDERED this 18" day of October 2019. (Awl 9 RICARDO S. MARTINEZ CHIEF UNITED STATES DISTRICT JUDGE So stipulated and presented by: INSLEE, BEST, DOEZIE & RYDER, P.S.

By | Gregory L. Ursich, WSBA No. 18614 Attorney for John Babarovich | 10900 NE 4" Street, Suite 1500 Bellevue, Washington 98004 | Tel: (425) 455-1234 Fax: (425) 635-7720999 | Email: [email protected] | So stipulated and copy received: | COZEN O’CONNOR Kevin A. Michael, WSBA # 36976 | Craig H. Bennion, WSBA #11646 Nadia A. Bugaighis, WSBA #45492 | Attorneys for Defendant Standard Guaranty Insurance Company | Third Avenue, Suite 1900 Seattle, WA 98104 | Tel: (206) 340-1000 24 STIPULATED MOTION AND AGREED ORDER - Page 3 eS INSLEE BES r 25 Attomeys at Law ; 10900 NE Ath Street, Suite 1500