Wadleigh v. Standard Guaranty Insurance Company

6 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 7 AT SEATTLE ROBERT W. WADLEIGH individually and as Successor Trustee and on behalf of the No. 2:24-cv-00126-RSM ROBERT R. AND MARGARET E.

WADLEIGH TRUST and the ROBERT R. STIPULATED MOTION AND ORDER AND MARGARET E. WADLEIGH TRUST, TO CONTINUE TRIAL AND AMEND a Washington trust. CASE SCHEDULE BY 90 DAYS

11 Plaintiffs, 12 v. STANDARD GUARANTY INSURANCE COMPANY, a foreign insurance company, Defendant.

I. STIPULATED MOTION The parties, by and through their undersigned counsel of record, have conferred and hereby stipulate and jointly request that the Court continue the trial date and amend the case schedule by 90 days pursuant to Fed. R. Civ. P. Rule 6 and LCR 10(g).

II. LEGAL AUTHORITY A. Applicable Legal Standard A case schedule may be modified only for good cause and with the judge’s consent. Fed. R. Civ. P. 16(b)(4); see also LCR 16(b)(6) (“A schedule may be modified only for good cause and with the judge’s consent.”). The decision to modify a scheduling order is within the broad discretion of the district court. See Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 607 (9th Cir. 1992).

3 B. Good Cause Exists to Extend the Trial Date and Pre-Trial Deadlines 4 Good cause exists for a continuance. The parties have been attempting to resolve this matter through settlement discussions. Plaintiffs have failed to communicate with their counsel, necessitating the withdrawal of counsel; a Motion to Withdraw has been filed. [Dkt. # 13] 7 Further it has now come to counsels’ attention that Plaintiffs have been directly contacting Defendant Standard Guaranty regarding the subject of this matter.

9 Plaintiffs have indicated, through words and/or conduct, that they wish to address this matter directly with Standard and not through current counsel, further demonstrated by their failure to respond to, or communicate in any way, with counsel, and necessitating current counsel for Plaintiffs to withdraw from this matter. The parties agree that a brief continuance is appropriate in order for Plaintiffs to either obtain new counsel and for counsel to familiarize themselves with the matter or for the parties to resolve the matter.

15 In light of the foregoing, the parties respectfully submit that good cause exists for a continuance. As this request is being made jointly by the parties, a short extension presents no prejudice to either party. Instead, a brief extension provides both parties the benefit of additional time to try to resolve the matter without the cost and expense of protracted litigation and discovery, to provide time for Plaintiffs to retain new counsel, and for that counsel to familiarize themselves with the matter.

21 For these reasons, the parties respectfully move the Court to amend the case schedule and extend the trial date in this matter by 90 days.

1 DATED this 16th day of July 2025.

2 LETHER LAW GROUP 3 /s/ Kevin J. Kay_____________ Kevin J. Kay, WSBA #34546 4 1848 Westlake Avenue N, Suite 100 Seattle, WA 98109 5 P: (206) 467-5444/F: (206) 467-5544 [email protected] 6 Counsel for Plaintiffs FREEMAN MATHIS & GARY, LLP /s/ Galina Kletser Jakobson 9 Galina Kletser Jakobson, WSBA #49501 3020 Issaquah-Pine Lake Rd. SE #263 10 Sammamish, WA 98075 [email protected] 11 Counsel for Defendant Standard Guaranty Insurance Company

III. ORDER The Court having reviewed the above Stipulated Motion, it is hereby ORDERED that the following deadlines are extended 90 days and the case schedule is amended as follows: EVENT DATE Reports from expert witnesses under FRCP October 14, 2025 26(a)(2) due Discovery completed by December 15, 2025 All dispositive motions must be filed by January 12, 2026 All motions in limine must be filed by March 16, 2026 Pretrial Order March 30, 2026 Trial Briefs submitted by April 7, 2026 Length of Jury Trial 3-5 days Trial Date April 13, 2026 DATED this 18th day of July, 2025.

14 A RICARDO S. MARTINEZ 16 UNITED STATES DISTRICT JUDGE