Andrade v. Cuccinelli

District Judge Marsha J. Pechman 5 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 6 AT SEATTLE

8 GERARDO SUSANO ANDRADE, NO. 2:20-cv-00692-MJP 9 Plaintiff, Stipulated Motion to Extend Deadlines v. 10 Note on Motion Calendar: September 11, 2020 KENNETH T. CUCCINELLI, et al.,

12 Defendants.

14 The parties, pursuant to Local Rules 10(g), hereby jointly stipulate and move for a one month extension of their initial scheduling deadlines. Dkt. No. 9. The parties submit there is good cause for an extension of these deadlines. The response to the complaint is currently due on October 5, 2020. This extension will allow Defendants to respond to the complaint before engaging in discussions about discovery. The parties also intend to discuss potential resolution of this matter that may avoid the need for further judicial intervention. The current and proposed deadlines are as follows: 22 Deadline Current Date Proposed Date FRCP 26(f) Conference September 11, 2020 October 9, 2020 Initial Disclosures September 18, 2020 October 16, 2020 Joint Status Report and October 5, 2020 November 2, 2020 Discovery Plan A court may modify a schedule for good cause. Fed. R. Civ. P. 16(b)(4). Continuing pretrial and trial dates is within the discretion of the trial judge. See King v. State of California, 784 F.2d 910, 912 (9th Cir. 1986). Accordingly, the parties seek a one month extension of their initial scheduling deadlines. Dkt. No. 9.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

7 DATED: September 11, 2020 s/ Alexandra Lozano ALEXANDRA LOZANO, WSBA #40478 8 Alexandra Lozano Immigration Law 16400 Southcenter Pkwy., Suite 410 Tukwila, WA 98188 10 Phone: 206-406-3068 Fax: 206-494-7775 11 Email: [email protected] 12 Attorney for Plaintiff

DATED: September 11, 2020 s/ Michelle R. Lambert MICHELLE LAMBERT, NYS #4666657 Assistant United States Attorney United States Attorney’s Office 1201 Pacific Ave, Suite 700 Tacoma, WA 98402 Phone: (253) 428-3824 Email: [email protected] Attorney for Defendants

ORDER

2 IT IS SO ORDERED.

Dated this 11th day of September, 2020.

A Marsha J. Pechman 8 United States Senior District Judge

STIPULATED MOTION TO EXTEND DEADLINES