Stodola v. City of Bellingham

1 The Honorable Tana Lin

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE MATTHEW STODOLA and LYNDSEY Case No. 2:24-cv-00004-TL STODOLA, on behalf of their minor child, V.S., STIPULATED MOTION AND 11 [PROPOSED] ORDER FOR STAY Plaintiffs, 12 v. Noted for Consideration: December 19, 2024 CITY OF BELLINGHAM and UNITED STATES OF AMERICA, Defendants.

16 JOINT STIPULATION 17 The parties stipulate and agree to a brief stay or extension of all dates in order to facilitate efforts to resolve this case for any time after June 20, 2025.

19 All parties have reached an agreement to settle this matter. Because one of the plaintiffs is a minor, Plaintiffs are in the process of seeking appointment of a settlement guardian ad litem through Washington State court and then the state court’s approval of the settlement. Assuming approval is granted, the parties intend to file a notice of voluntary dismissal pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(ii).

1 Plaintiffs’ counsel has informed that parties that the SGAL appointment and court approval process could take between three to six months. In light of that, the parties request that the case be stayed for six months so Plaintiffs may finalize the state court approval process.

4 As all issues have been resolved and the parties intend to dismiss with prejudice and without costs or fees to any party, there are no claims or defenses left to litigate. There is good cause for a stay, which will preserve the Court’s and the parties’ resources. See King v. State of California, 784 F.2d 910, 912 (9th Cir. 1986). Thus the parties stipulate to this motion and respectfully request that the Court strike all deadlines and stay the matter until June 20, 2025.

10 DATED this 19th day of December, 2024.

11 // // // // // // // // // // // // // 1 Respectfully submitted, TESSA M. GORMAN BRETT MCCANDLIS BROWN & United States Attorney CONNER s/ Nickolas Bohl NICKOLAS BOHL, WSBA #48978 s/ Scott Kirk Assistant United States Attorney SCOTT KIRK, WSBA #51115 United States Attorney’s Office 200 West Chestnut Street Western District of Washington Bellingham, WA 98225 700 Stewart Street, Suite 5220 Phone: 360-714-0900 Seattle, Washington 98101-1271 Fax: 866-437-0623 Phone: 206-553-7970 Email: [email protected] Fax: 206-553-4073 Email: [email protected] Attorney for Plaintiffs Attorneys for United States of America CITY OF BELLINGHAM I certify that this memorandum contains 228 words, in compliance with the Local Civil s/ Michael E. Good Rules. MICHAEL E. GOOD, WSBA #44857 Lottie Street 12 Bellingham, WA 98225 Phone: 360-778-8270 13 Fax: 360-778-8271 Email: [email protected] Attorney for City of Bellingham [PROPOSED] ORDER It is so ORDERED.

DATED this 19th day of December, 2024.

A Tana Lin 23 United States District Judge