Alfarag v. DeJoy

1 The Honorable Marsha J. Pechman

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE MAJID ALFARAG, Case No. 2:22-cv-01745-MJP Plaintiff, STIPULATED MOTION AND 11 v. [PROPOSED] ORDER FOR EXTENSION OF TIME TO RESPOND TO MOTION FOR LOUIS DEJOY, Postmaster General, U.S. JUDGMENT ON THE PLEADINGS AND Postal Service, CORRESPONDING MODIFICATION OF 13 CASE SCHEDULE Defendant.

14 Noted for Consideration: May 8, 2024 16 As a result of Plaintiff’s request for more time to search for legal representation, the parties hereby STIPULATE, AGREE and JOINTLY REQUEST an order extending the response and corresponding reply deadlines for Defendant’s Motion for Judgment on the Pleadings by 60 days modifying the deadlines set forth in the Court’s July 21, 2023, Order Setting Trial and Related Dates (Dkt. 22), as follows: 1 Current Proposed New Deadline Deadline Deadline Plaintiff’s Response to Defendant’s Motion for 5/13/2024 7/15/2024 Judgment on the Pleading due by Defendant’s Reply in Support of Motion for 4 5/17/2024 7/19/2024 Judgment on the Pleadings due by Discovery completed by 5/20/2024 7/19/2024 All dispositive motions must be filed by 6/17/2024 8/16/2024 8 In addition, the parties ask the Court to set a new trial date of no earlier than December 16, 2024, with all trial related deadlines set corresponding to the new trial date. The parties have set forth their current scheduling conflicts below: Plaintiff: Defendant: December 26, 2024–January 3, 2025; January 14–20, 2025; February 24–March 11, 2025; April 14–18, 20205; May 12–15, 2025.

14 A court may modify a schedule for good cause. Fed. R. Civ. P. 16(b)(4). Continuing pretrial and trial dates is within the discretion of the trial judge. King v. State of California, 784 F.2d 910, 912 (9th Cir. 1986). Good cause exists for extending the specific deadlines noted above, as Plaintiff is requesting additional time to respond to Defendant’s Motion in order to seek counsel. Defendant joins in the request in order to provide Plaintiff sufficient time.

19 // // // // // 1 SO STIPULATED.

2 DATED this 8th day of May, 2024.

3 Respectfully submitted, TESSA M. GORMAN United States Attorney s/ Rebecca S. Cohen s/ Majid Alfarag REBECCA S. COHEN, WSBA No. 31767 Majid Alfarag 10032 Edmonds Way, Apt 210 s/ Alixandria K. Morris Edmonds, WA 98020 ALIXANDRIA K. MORRIS, TX No. 24095373 Phone: 509-879-4237 Assistant United States Attorneys Email: [email protected] United States Attorney’s Office Western District of Washington Pro Se Plaintiff Stewart Street, Suite 5220 Seattle, Washington 98101-1271 Phone: 206-553-7970 Fax: 206-553-4073 Email: [email protected] Email: [email protected] Attorneys for Defendant DeJoy I certify that this memorandum contains 258 words, in compliance with the Local Civil Rules.

1 ORDER 2 It is hereby ORDERED that the parties’ motion is GRANTED.

4 DATED this 8th day of May, 2024.

A MARSHA J. PECHMAN 8 United States Senior District Judge