Sungh Boparai v. Auburn Police Department

1 THE HONORABLE JAMAL N. WHITEHEAD

UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE GURDEEP SINGH BOPARAI, Plaintiff, Case No. 2:23-cv-00825-JNW v. STIPULATED MOTION FOR STAY OF 12 PROCEEDINGS PENDING LCR 39.1 CHASE WIGER, in his individual and official MEDIATION capacity, JACOB GARCIA in his individual and official capacity, JASON PENNOCK, in his individual and official capacity, ANDREW MANN, in his individual and official capacity, NOTE ON MOTION CALENDAR: MARCH 22, 2024 AVALYNE PETERS, in her individual and official capacity, DAVID LIND, in his individual and official capacity, and the CITY OF AUBURN, Defendants.

STIPULATED MOTION FOR STAY OF PROCEEDINGS M ,L &B LLP 1 Plaintiff Gurdeep Singh Boparai and Defendants Chase Wiger, Jacob Garcia, Jason Pennock, Andrew Mann, Avalyne Peters, David Lind, and the City of Auburn (collectively “the Parties”), respectfully advise the Court that they have agreed to pursue mediation pursuant to Local Civil Rule 39.1.

5 The Parties request that the Court stay any current deadlines in this case for at least 120 days or until early mediation is complete, including the deadline to provide a joint proposed schedule modifying the early case deadlines, Dkt. No. 22. See Fed. R. Civ. P. 16(b)(4) (noting that “[a] schedule may be modified only for good cause and with the judge’s consent.”); see also Zivkovic v. S. Cal. Edison Co., 302 F.3d 1080, 1087 (9th Cir. 2002). Good cause exists to modify existing case deadlines so that the parties may focus on settlement through mediation and avoid spending additional resources on further litigation.

12 Pursuant to Local Civil Rule 39.1(c)(4), the Parties have asked for a mediator appointed by the ADR Committee Co-Chair(s). The parties propose that they file a Joint Status Report within seven (7) days of a mediator being selected to inform the Court of the date of the mediation, and that they file a further Joint Status Report within seven (7) days after mediation to inform the Court on the outcome of the mediation and the status of settlement negotiations.

STIPULATED MOTION FOR STAY OF PROCEEDINGS M ,L &B LLP 1 STIPULATED AND SUBMITTED TO this March 22, 2024 MORGAN, LEWIS & BOCKIUS LLP LAW, LYMAN, DANIEL, KAMERRER & BOGDANOVICH, P.S.

4 By: /s/ Harold Malkin Harold Malkin, WSBA #30986 By: /s/ Michael J. Throgmorton Austin Popham, WSBA #59193 Michael J. Throgmorton, WSBA #44263 Ari M. Sillman, WSBA # 60798 2674 RW Johnson Rd., 1301 Second Avenue, Suite 3000 Tumwater, WA 98512 P.O. Box 11880 Seattle, WA 98101 Olympia WA 98508-1880 Phone: (206) 274-6400 Telephone: (360) 754-3480 [email protected] Fax: (360) 754-3511 [email protected] [email protected] [email protected] Attorneys for Plaintiff Attorney for Defendants

STIPULATED MOTION FOR STAY OF PROCEEDINGS M ,L &B LLP 1 ORDER 2 IT IS SO ORDERED.

3 DATED: March 22, 2024.

A Jamal N. Whitehead United States District Judge Presented by: MORGAN, LEWIS & BOCKIUS LLP By: /s/ Harold Malkin Harold Malkin, WSBA #30986 Austin Popham, WSBA #59193 Ari M. Sillman, WSBA # 60798 1301 Second Avenue, Suite 3000 Seattle, WA 98101 Phone: (206) 274-6400 [email protected] [email protected] [email protected] Attorneys for Plaintiff STIPULATED MOTION FOR STAY OF PROCEEDINGS M ,L &B LLP