Craig v. United States

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT TACOMA BRIANA CRAIG, et al., Case No. 3:24-cv-05421-JHC Plaintiffs, STIPULATED MOTION AND 11 ORDER FOR EXTENSION OF EXPERT v. DISCLOSURE DEADLINES UNITED STATES OF AMERICA, Noted for Consideration: 13 July 2, 2025 Defendant.

15 The parties hereby jointly STIPULATE AND AGREE to extend the expert disclosure deadlines set forth in the Court’s September 19, 2024, Order Setting Trial Date and Related Dates (Dkt. 11), and the Federal Rules of Civil Procedures, as set forth below.

18 Proposed New Deadline Current Deadline Deadline Disclosure of expert testimony under July 7, 2025 July 14, 2025 FRCP 26(a)(2) Disclosure of rebuttal expert testimony August 6, 20251 August 13, 2025 The Court’s scheduling order does not specify a deadline for rebuttal expert testimony, so the current deadline is calculated pursuant to Fed. R. Civ. P. 26(a)(2)(D)(ii).

1 No modification to the trial date or any other pre-trial deadlines is requested.

2 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). The parties submit that good cause exists for extending these expert disclosure deadlines. The parties have been working diligently to complete discovery in this case, but only received pathology slides necessary for certain experts to complete their analyses in the last week.

7 Because the parties’ experts need time to review the slides, a short, one-week extension will make it more efficient for expert witnesses to have access to this information before the disclosure deadline to avoid duplicative efforts based on new information.

10 For the reasons 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.

12 DATED this 2nd day of July, 2025.

13 Respectfully submitted, 14 TEAL LUTHY MILLER Acting United States Attorney s/ James C. Strong 16 JAMES C. STRONG, WSBA No. 59151 Assistant United States Attorney 17 United States Attorney’s Office Western District of Washington 18 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 19 Phone : 206-553-7970 Email : [email protected] Attorneys for United States of America I certify that this memorandum contains 262 words, 22 in compliance with the Local Civil Rules.

1 BAILEY ONSAGER 2 s/ Darrin E. Bailey Darrin E. Bailey, WSBA No. 34955 3 1109 First Avenue, Suite 501 Seattle, Washington 98101 4 Telephone: (206) 667-8290 Email: [email protected] FRIEDMAN RUBIN s/ Peter J. Mullenix 7 Peter J. Mullenix, WSBA No. 37171 1109 First Avenue, Suite 501 8 Seattle, Washington 98101 Phone: (206) 504-4446 9 Email: [email protected] 10 Attorneys for Plaintiff 1 ORDER 2 It is hereby ORDERED that the parties’ motion is GRANTED. The new deadlines are as ||follows: Disclosure of expert testimony under FRCP 26(a)(2) July 14, 2025 7 Disclosure of rebuttal expert testimony August 13, 2025 DATED this__3rd__ day of July , 2025.

11 c Jette □ Chur JOHN/‘H. CHUN 12 United States District Judge STIPULATED MOTION AND ORDER FOR EXTENSION OF EXPERT DISCLOSURE DEADLINES