Scott v. Carr

1 Hon. Ricardo S. Martine UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 8 PAUL SCOTT, an individual, NO. 2:20-cv-00236-RSM 9 Plaintiff, v. 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 their 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, on September 14, 2020, the Court entered a Stipulated Motion and Order For Extension of Certain Deadlines (Dkt. No. 45); STIPULATED MOTION AND ORDER FOR ceueere EXTENSION OF CERTAIN DEADLINES - 1 RUSS Case No. 2:20-cv-00236-RSM Sid Boe ees AE 1 WHEREAS, due to the continued unprecedented effects of the COVID-19 pandemic, || and the challenges and difficulties associated with conducting discovery while Washington’s || stay-at-home order was in effect and while each parties’ attorneys’ physical offices continues ||to 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; 6 WHEREAS, the parties have agreed to extend certain deadlines due to the due to the || challenges and difficulties associated with conducting discovery, including illness of defense || counsel’s staff, and other impacts associated with COVID 19; 9 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.

15 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 August 2, 2021 to August 23, 2021 or as || soonest thereafter as the Court permits, and the following deadlines in the shall be modified as || set forth below: Event Title Current Deadline Proposed Amended —_ =

STIPULATED MOTION AND ORDER FOR | | ceueere EXTENSION OF CERTAIN DEADLINES - 2 RUSS Case No. 2:20-cv-00236-RSM cendiew Sa 1 All Motions Related to non-expert January 27, 2021 March 29, 2021 Discovery must be filed by (see LCR 2 7d) Disclosure of Expert Testimony under March 5, 2021 May 4, 2021 3 FRCP 26(a)(2) 4 Discovery Completed by April 30, 2021 June 29, 2021 5 All dispositive motions must be May 7, 2021 July 6, 2021 filed by and noted on the motion 6 calendar no later than the fourth Friday thereafter 7 (see LCR 7(d)) 8 Mediation per LCR 39.1(c)(3), if June 18, 2021 June 18, 2021 requested by the parties, held no later 9 than || | All motions in limine must be filed by —_| July 9, 2021 July 9, 2021 and noted on the motion calendar no 11 later than the THIRD Friday thereafter 12 Agreed pretrial order due July 21, 2021 July 21, 2021 13 Pretrial conference to be scheduled by the Court.

Trial briefs, proposed voir dire questions, | July 28, 2021 July 28, 2021 I5 jury instructions, neutral statement of 16 the case, and trial exhibits due 7 DATED this 31st day of December, 2020.

8 TOMLINSON BOMSZTYK RUSS By: /s/Abigail Z. Staggers 19 Abigail Staggers, WSBA No. 43962 Blair M. Russ, WSBA No. 40374 20 1000 Second Avenue, 3660 Seattle, WA 98104 21 Phone: (206) 621-1871 Fax: (206) 621-9907 22 Email: [email protected] [email protected] 23 Attorneys for Plaintiff Scott STIPULATED MOTION AND ORDER FOR ceueere EXTENSION OF CERTAIN DEADLINES - 3 RUSS Case No. 2:20-cv-00236-RSM Sid Boe ees AE BETTS PATTERSON MINES 3 By: /s/Anne Cohen (w/permission Anne Cohen, WSBA No. 41183 4 Betts Patterson Mines 111 SW 5" Avenue, Suite 3650 5 Portland, Oregon 97204 acohen @bpmlaw.com Attorney for Defendants Carr and 7 Vita STIPULATED MOTION AND ORDER FOR ceueere EXTENSION OF CERTAIN DEADLINES - 4 RUSS Case No. 2:20-cv-00236-RSM iis eel Irene Sas: 1 ORDER 2 Based on the foregoing, IT IS SO ORDERED.

DATED: January 4, 2021.

Laws (J 7 RICARDO S. MARTINEZ CHIEF UNITED STATES DISTRICT JUDGE Presented by: TOMLINSON BOMSZTYK RUSS || By: 4s/ Abigail Z. Staggers Abigail 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] 16 bmr @tbr-law.com || 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 || [email protected] || Attorney for Defendants Carr and Vita TOMLINSON STIPULATED MOTION AND ORDER FOR BOMSZTYK EXTENSION OF CERTAIN DEADLINES - 5 RUSS Case No. 2:20-cv-00236-RSM Sl Seon SAGAS