Babarovich v. Standard Guaranty Insurance Company

1 Honorable Ricardo S. Martinez IN THE UNITED STATES DISTRICT COURT 7 FOR THE WESTERN DISTRICT OF WASHINGTON AT SEATTLE 8 JOHN BABAROVICH, NO. 2:19-CV-01395 9 Plaintiff, STIPULATED MOTION AND AGREED 10 vs. ORDER TO EXTEND CASE DEADLINES 11 STANDARD GUARANTY INSURANCE COMPANY, a Delaware Corporation, Defendant.

14 STIPULATED MOTION 15 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 January 7, | 2020 Order Setting Trial and Related Dates (Dkt. 16), file this Joint Motion to extend the case | scheduling deadlines set forth below. In support of this Stipulated Motion, the Parties show the | Court as follows: 21 The Court set the current case schedule shortly before the COVID-19 pandemic began.

22 Dkt. 16. Since the onset of the pandemic, the Parties have had difficulty meeting with and 23 working with their experts, who have been indisposed or otherwise unable to perform the 24 STIPULATED MOTION AND AGREED ORDER - Page 1 I NN aboot eon. □ 5 Attorneys at Law 10900 NE Ath Street, Suite 1500 | expected services. In addition, Plaintiff John Babarovich is in the midst of cancer treatment, | making it more difficult for him to meet with counsel and experts, prepare for and sit for | deposition, etc. In addition, the Parties desire to explore resolution before undertaking additional | discovery efforts. Finally, in the event that resolution does not occur, the Parties desire to set a | case schedule that allows for the completion of all fact discovery, followed by a period for expert reports and expert depositions. The Parties have conferred and propose the following case | schedule: 8 BENCH TRIAL DATE July 26, 2021 9 Deadline for discovery motions December 4, 2020 10 Fact discovery deadline January 15, 2021 11 Initial expert report deadline February 12, 2021 12 Rebuttal expert report deadline March 5, 2021 13 Expert deposition deadline March 19, 2021 14 Dispositive motion deadline April 16, 2021 15 Motions in limine deadline June 18, 2021 16 Agreed pre-trial order July 2, 2021 17 Trial briefs and proposed findings of fact and July 16, 2021 conclusions of law, designations of deposition 18 testimony, and trial exhibits THEREFORE, the Parties jointly move the Court for an Order extending the deadlines as reflected above. Attached is a proposed Order granting the Joint Motion.

24 STIPULATED MOTION AND AGREED ORDER - Page 2 INSL = BEST 2 eee INSLEE BEST DOEZIE & RYDER, P.S. COZEN O’ CONNOR 2 ___/S/ KEVIN A. MICHAEL Gregory L. Ursich WSBA #18614 Kevin A. Michael WSBA #36976 | Attorney for Plaintiff John Babarovich Attorney for Defendant Standard Guaranty Insurance Company DATED on this day of Sept., 2021 DATED on this day of Sept., 2021 6 AGREED ORDER IT IS, based on the above stipulation of counsel for all Parties, hereby ORDERED that the pending deadlines are extended as follows: BENCH TRIAL DATE July 26, 2021 Deadline for discovery motions December 4, 2020 Fact discovery deadline January 15, 2021 Initial expert report deadline February 12, 2021 Rebuttal expert report deadline March 5, 2021 Expert deposition deadline March 19, 2021 Dispositive motion deadline April 16, 2021 Motion in limine deadline June 18, 2021 Agreed pre-trial order July 2, 2021 Trial briefs and proposed findings of fact and July 16, 2021 19 conclusions of law, designations of deposition testimony, and trial exhibits 24 STIPULATED MOTION AND AGREED ORDER - Page 3 I Na der Bebo. x 25 10900 NE ath street, Sule 1500 ] IT IS SO ORDERED this 21" day of September, 2020.

Baldy 4 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: 14. | COZEN O’CONNOR | /s/ Kevin A. MICHAEL Kevin A. Michael, WSBA # 36976 | 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 4 I NN aboot eon. □ 5 Attorneys at Law 10900 NE Ath Street, Suite 1500