Guzman Reyes v. United States

UNITED STATES DISTRICT COURT FOR THE 7 WESTERN DISTRICT OF WASHINGTON AT SEATTLE M.S.G.L., by and through her parents Case No. 2:22-cv-01554-KKE GREGORIO GUZMAN REYES and MARICRUZ LOPEZ SANTOS, and ORDER GRANTING STIPULATED individually, MOTION FOR EXTENSION OF TRIAL 11 AND PRETRIAL DEADLINES Plaintiffs, 12 v. UNITED STATES OF AMERICA, 14 Defendant.

JOINT STIPULATION The parties hereby jointly STIPULATE AND AGREE to extend the following deadlines, which were set in the Court’s October 24, 2024, Order Amending Trial Date and Related Dates (Dkt. 34), and the Court’s March 20, 2025 Order granting Stipulated Motion for Extension of Pretrial Deadlines, as set forth below.

Proposed New 21 Deadline Current Deadline Deadline BENCH TRIAL September 15, 2025 December 8, 2025 Disclosure of rebuttal expert testimony April 3, 2025 April 18, 2025 Discovery completed by May 2, 2025 June 30, 2025 Dispositive Motions and motions challenging expert witness testimony (see LCR 7(d)). Such motions must be noted May 19, 2025 August 11, 2025 for consideration no later than the fourth Friday thereafter (see LCR 7(d)).

5 Settlement conference, if mediation has been requested by the parties per LCR July 17, 2025 October 6, 2025 39.1, held no later than Agreed LCR 16.1 Pretrial Order due, including exhibit list with completed August 25, 2025 October 13, 2025 authenticity, admissibility, and objections fields Trial briefs, joint brief on motions in limine, preliminary proposed findings of September 2, 2025 November 17, 2025 fact and conclusions of law, and deposition designations due Pretrial Conference TBD TBD 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, (9th Cir. 1986). Good cause exists to continue the trial and pretrial deadlines as set out above.

The parties have been diligent in completing the discovery in this case, including setting deposition dates for expert witnesses. Plaintiff’s expert was scheduled to be deposed on April 8, 2025. The parties learned on Monday, March 24, 2025, that the expert needs to deal with health concerns and will not be available for deposition until June 10 or June 12, 2025. Because the deposition will need to take place after the Court’s current dispositive motions deadline, moving the remaining deadlines will allow the parties time to assess the need for and file dispositive motions or motions to exclude, if any. The parties now request to move the trial date and remaining pretrial deadlines to accommodate the deposition of this expert.

1 For the reason set forth above, the parties believe that there is good cause to request an extension of the above-listed dates and respectfully request that the Court grant their motion.

3 SO STIPULATED.

4 DATED this 26th day of March, 2025.

5 Respectfully submitted, TEAL LUTHY MILLER GEORGIA TREJO LOCHER, P.S.

Acting United States Attorney s/ Whitney Passmore s/ Georgia Trejo Locher WHITNEY PASSMORE, FL No. 91922 GEORGIA TREJO LOCHER, WSBA No. 21450 Assistant United States Attorney 237 SW 153rd St. United States Attorney’s Office Burien, WA 98166 Western District of Washington Phone: 206-246-6100 700 Stewart Street, Suite 5220 Fax: 206-246-6105 Seattle, Washington 98101-1271 Email: [email protected] Phone: 206-553-7970 Fax: 206-553-4073 Attorney for Plaintiffs Email: [email protected] Attorneys for United States of America I certify that this memorandum contains words, in compliance with the Local Civil Rules.

1 ORDER 2 It is hereby ORDERED that the parties’ motion is GRANTED. The new trial and pretrial deadlines are as follows: Deadline New Deadline 10-Day BENCH TRIAL December 8, 2025 Disclosure of rebuttal expert testimony April 18, 2025 Discovery completed by June 30, 2025 Dispositive Motions and motions challenging expert witness testimony (see LCR 7(d)). Such motions must be noted for 10 August 11, 2025 consideration no later than 28 days after this date (see LCR 7(d)).

Settlement conference, if mediation has been requested by the October 6, 2025 12 parties per LCR 39.1, held no later than Agreed LCR 16.1 Pretrial Order due, including exhibit list 13 with completed authenticity, admissibility, and objections October 13, 2025 fields 14 Trial briefs, joint brief on motions in limine, preliminary proposed findings of fact and conclusions of law, and November 17, 2025 15 deposition designations due 16 Pretrial Conference TBD 18 DATED this 27th day of March, 2025.

A Kymberly K. Evanson 22 United States District Judge