Scott v. Carr

] Hon. Ricardo S. Martine UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE g PAUL SCOTT, an individual, NO. 2:20-cv-00236-RSM 9 Plaintiff, Vv. STIPULATED MOTION AND 10 ORDER FOR EXTENSION OF CALEB CARR, individually; and VITA CERTAIN DEADLINES 11 INCLINATA TECHNOLOGIES INC., a Delaware Corporation, as a nominal 12 Defendant, 13 Defendants.

WHEREAS, on April 7, 2020, the Court issued an Order Setting Trial Date and Related Dates (Dkt. No. 27); WHEREAS, in Part B of the parties’ Joint Status Report and Discovery Plan the parties jointly represented to the Court the perceived difficulties in their scheduling needs due to the unprecedented effects of the COVID-19 pandemic and their commitment to work cooperatively with one another to accommodate each other during these unprecedented times (Dkt. No. 24); WHEREAS, due to the continued unprecedented effects of the COVID-19 pandemic, and the challenges and difficulties associated with conducting discovery while Washington’s STIPULATED MOTION AND ORDER FOR Bese EXTENSION OF CERTAIN DEADLINES - 1 RUSS Case No. 2:20-cv-00236-RSM 1000 Second Avenue, Suite 3660, || stay-at-home order was in effect and while each parties’ attorneys’ physical offices continues 2 remain closed as of present, the parties believe that a change to the dates and schedule || previously set by the Court and agreed to by the parties is necessary; 4 WHEREAS, the parties have agreed to extend certain deadlines due to the due to the || challenges and difficulties associated with conducting discovery and other impacts associated |} with COVID 19; 7 WHEREAS, the parties believe that the Court is well acquainted with the circumstances || of this national health emergency, and is more than likely aware of the general nature of the || impact on law firms during this uncertain time; however, should the Court require declarations || explaining the impact of the COVID-19 pandemic of their respective counsel’s law firms, the || parties are more than willing to articulate specific circumstances supporting good cause for || this modification.

13 IT IS HEREBY STIPULATED AND AGREED by and through the undersigned || counsel for Plaintiff and Defendant, in accordance with LCR 7(d)(1) and 10(g), subject to the || approval of the Court, that trial be continued from April 5, 2021 to August 2, 2021 or as soonest || thereafter as the Court permits, and the deadlines in the shall be modified as set forth below: Event Title Current Deadline Proposed Amended 18 Deadline 19 JURY TRIAL DATE April 5, 2021 August 2, 2021 All Motions Related to non-expert November 6, 2020 January 27, 2021 20 Discovery must be filed by (see LCR 7(d 21 Disclosure of Expert Testimony under (expert disclosures: March 5, 2021 FRCP 26(a)(2) October 7, 2020; Discovery Completed by December 7, 2020 April 30, 2021 STIPULATED MOTION AND ORDER FOR Bese EXTENSION OF CERTAIN DEADLINES - 2 RUSS Case No. 2:20-cv-00236-RSM 1000 Second Avenue, Suite 3660, 1 All dispositive motions must be January 5, 2021 May 7, 2021 filed by and noted on the motion 2 calendar no later than the fourth Friday thereafter 3 (see LCR 7(d)) 4 Mediation per LCR 39.1(c)(3), if February 19, 2021 June 18, 2021 requested by the parties, held no later 5 than 6 All motions in limine must be filed by March 8, 2021 July 9, 2021 and noted on the motion calendar no 7 later than the THIRD Friday thereafter 8 Agreed pretrial order due March 24, 2021 July 21, 2021 9 Pretrial conference to be scheduled by the Court.

Trial briefs, proposed voir dire questions, | March 31, 2021 July 28, 2021 11 jury instructions, neutral statement of the case, and trial exhibits due 13 DATED this 11" day of September, 2020.

14 TOMLINSON BOMSZTYK RUSS BETTS PATTERSON MINES By: /s/ Blair M. Russ By: /s/ Anne Cohen (w/permission) 16 Abagail Staggers, WSBA No. 43962 Anne Cohen, WSBA No. 41183 Blair M. Russ, WSBA No. 40374 Betts Patterson Mines || 1000 Second Avenue, 3660 111 SW 5" Avenue, Suite 3650 Seattle, WA 98104 Portland, Oregon 97204 18 Phone: (206) 621-1871 Phone: (503) 961-6540 Fax: (206) 621-9907 Fax: (503) 961-6339 19 Email: [email protected] Email: [email protected] [email protected] 5 Attorneys for Plaintiff Scott Attorney for Defendants Carr and Vita

STIPULATED MOTION AND ORDER FOR Bese EXTENSION OF CERTAIN DEADLINES - 3 RUSS Case No. 2:20-cv-00236-RSM 1000 Second Avenue, Suite 3660, 1 ORDER 2 Based on the foregoing, IT IS SO ORDERED.

DATED this 14" day of September, 2020. . (AWA RICARDO S. MARTINEZ 7 CHIEF UNITED STATES DISTRICT JUDGE Presented by: TOMLINSON BOMSZTYK RUSS || By: /s/ Blair M. Russ Abagail Staggers, WSBA No. 43962 || Blair M. Russ, WSBA No. 40374 1000 Second Avenue, 3660 || Seattle, WA 98104 Phone: (206) 621-1871 || Fax: (206) 621-9907 Email: [email protected] 15 [email protected] || Attorneys for Plaintiff Scott || BETTS PATTERSON MINES By: /s/ Anne Cohen (w/permission) |} Anne Cohen, WSBA No. 41183 Betts Patterson Mines |] 111 SW 5" Avenue, Suite 3650 Portland, Oregon 97204 21 Phone: (503) 961-6540 Fax: (503) 961-6339 || Email: [email protected] || Attorney for Defendants Carr and Vita STIPULATED MOTION AND ORDER FOR Beneet a EXTENSION OF CERTAIN DEADLINES - 4 RUSS Case No. 2:20-cv-00236-RSM 1000 Second Avenue, Suite 3660,