Hajile Ansari v. United States of America

1 The Honorable Kymberly K. Evanson

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT TACOMA HAJILE ANSARI, Case No. 3:24-cv-05918-KKE Plaintiff, FIRST STIPULATED MOTION TO 11 v. MODIFY SCHEDULING ORDER AND ORDER UNITED STATES OF AMERICA, 13 Defendant.

15 JOINT STIPULATION 16 The parties hereby jointly STIPULATE AND AGREE to extend the following deadlines, which were set forth in the Court’s March 25, 2025, Order Setting Bench Trial Date and Related Dates (Dkt. 16), as set forth below.

19 Proposed New Deadline Current Deadline Deadline BENCH TRIAL 6/1/2026 7/27/2026 Disclosure of rebuttal expert testimony (per FRCP 26(a)(2)(D)(ii) 12/3/2025 2/2/2026 All motions related to discovery must be 12/3/2025 2/2/2026 filed by Discovery completed by 1/2/2026 3/2/2026 All dispositive motions and motions challenging expert witness testimony must be filed by this date (see LCR 7(d)).

2/2/2026 4/2/2026 Such motions must be noted for consideration no later than 28 days after this date (see LCR 7(d)).

Settlement conference, if mediation has been requested by the parties per LCR 4/2/2026 6/2/2026 39.1, held no later than Agreed LCR 16.1 Pretrial Order due, including exhibit list with completed 5/11/2026 7/10/2026 authenticity, admissibility, and objections fields Trial briefs, joint brief on motions in limine, preliminary proposed findings of 5/18/2026 7/17/2026 fact and conclusions of law, and deposition designations due Pretrial conference TBD TBD 13 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). Due to the government shutdown and lapse in appropriations to the Department of Justice, Plaintiff has agreed to stipulate to a 60-days extension of the above- referenced deadlines. The parties respectfully request that the Court find good cause to extend the above-referenced deadlines. This is the parties’ first request for an extension of any deadline in this case.

20 // 21 // 22 // 1 SO STIPULATED.

2 DATED this 10th day of November, 2025.

4 CHARLES NEIL FLOYD United States Attorney s/ Kristen R. Vogel 6 KRISTEN R. VOGEL, NY No. 5195664 Assistant United States Attorney 7 United States Attorney’s Office Western District of Washington 8 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 9 Phone: 206-553-7970 Fax: 206-553-4073 10 Email: kristen. vogel@usdo].gov 11 Attorney for Defendant . □□ 14 □□□ □□ Lyccu 15 MARIE DOCTER, WSBA No. 30557 BRIGGS & BRIGGS 16 10222 Gravelly Lake Drive SW Lakewood, Washington 98499 7 Phone: 253-588-6696 Fax: 253-584-6238 18 Email: [email protected] 19 Attorney for Plaintiff STIPULATED MOTION TO MODIFY SCHEDULING ORDER UNITED STATES ATTORNEY [Case No. 3:24-cv-05918-KKE] - 3 700 STEWART STREET, SUITE 5220 1 ORDER 2 The Court finds good cause to GRANT the parties’ motion. Dkt. No. 18. The prior case schedule is VACATED (Dkt. No. 16), and the courtroom deputy is directed to issue a new case schedule in accordance with the parties’ stipulated motion.

5 DATED this 10th day of November, 2025.

A Kymberly K. Evanson 9 United States District Judge