Holaday v. KeyBank National Association

Honorable Ricardo S. Martinez 8 UNITED STATES DISTRICT COURT 9 WESTERN DISTRICT OF WASHINGTON AT SEATTLE MARK HOLADAY, 11 Plaintiff, Case No. 19-cv-01199-RSM 12 v. STIPULATED MOTION TO AMEND DISCOVERY MOTIONS DEADLINE KEYBANK N.A., Noted for Hearing: 7/13/21 (w/o oral 14 Defendant. argument) 16 Plaintiff Mark Holaday and defendant KeyBank NA are cooperating and anticipate wrapping up discovery without asking the Court to get involved. But the discovery motions 18 deadline is currently scheduled for July 15, 2021, and there is still a bit more work to do. The parties request an extension of that deadline until August 12, 2021.

20 The Court may modify a deadline in its pretrial order for good cause. FRCP 16(b)(4); see 21 also Nikfard v. State Farm Fire & Cas. Co., 2020 WL 6491368, at *1 (W.D. Wash. Oct. 6, 2020).

22 extension of the discovery motions deadline prevents either party from filing an unnecessary 23 motion merely to preserve its rights while they continue to cooperate. And because all other pretrial — deadlines and trial dates would remain the same, resolution of this case will not be further delayed.

For those reasons, good cause exists for the extension.

STIPULATED MOTION TO AMEND DISCOVERY Mirrontens at tal MOTIONS DEADLINE - 1 ER TON ] IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

2 DATED: July 13, 2021 s/ Setareh Mahmoodi 3 Setareh Mahmoodi, WSBA No. 44288 Attorney for Plaintiff DATED: July 13, 2021 s/Kellen A. Hade 5 Kellen A. Hade, WSBA No. 44535 Attorney for Defendant PURSUANT TO STIPULATION, IT IS SO ORDERED. g DATED: __July 15, 2021 9 awfdg~ 10 Ricardo S. Martinez Chief United States District Court Judge 4853-1308-0561.1 STIPULATED MOTION TO AMEND DISCOVERY MILLER NASH LLP MOTIONS DEADLINE - 2 1 206.674.8300 | F 206.340.9988