Randa R. Mikel, Riad R. Mikel, and the martial community comprised thereof v....

1 The Honorable John C. Coughenour

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT TACOMA RANDA R. MIKEL, RIAD R. MIKEL, and Case No. 3:24-cv-05689-JCC the martial community comprised thereof, JOINT STATUS REPORT; JOINT MOTION 11 Plaintiffs, FOR EXTENSION OF DEADLINES; AND PARTIES’ [PROPOSED] ORDER v. Noted for Consideration: UNITED STATES OF AMERICA, et al., 13 November 26, 2025.

Defendants.

15 JOINT STATUS REPORT 16 Pursuant to this Court’s Order granting Defendant United States’ Stipulated Motion to Stay in Light of the Lapse of Appropriations (Dkt. 22), the parties submit this Joint Status Report. The Court’s Order (Dkt. 22) directs the parties to advise whether they believe an extension of the current case schedule is necessary. All parties agree that an extension is warranted and have conferred to develop a mutually acceptable revised schedule, as set forth below.

21 The parties therefore jointly STIPULATE and AGREE to extend the deadlines established in the Court’s August 5, 2025, Order Setting Trial Date and Related Dates (Dkt. 20) (“the Order”).

23 Under Federal Rule of Civil Procedure 16(b)(4), “[a case] schedule may be modified only for good cause and with the judge’s consent.” See also LCR 16(b)(6) (same). The decision to modify a scheduling order lies within the broad discretion of the district court. Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 607 (9th Cir. 1992).

3 Good cause exists to amend the deadlines in the Order due to the 43-day federal lapse in appropriations and for the reasons previously set forth in the Government’s Motion to Stay (Dkt.

5 21). The Parties proposed order adjusts all deadlines by 43 days due to this lapse. The lapse in appropriations prevented the parties’ ability to schedule and conduct necessary discovery. The parties require an extension to ensure there is sufficient time to complete remaining discovery, including depositions and necessary IMEs of Plaintiff Randa Mikel who is located in Florida.

9 Additionally, one of the United States’ counsel is currently on parental leave, with an anticipated return date of January 21, 2026, further supporting the need for the requested extensions.

11 Accordingly, the parties jointly and respectfully request that the Court extend the deadlines in the Order as set forth below: 13 Case Event Current Deadline Proposed Deadline (ECF No. 20) TBD [A date convenient for BENCH TRIAL August 10, 2026 the Court not earlier than September 22, 2026] Discovery completed by March 16, 2026 April 28, 2026 39.1 Mediation to be COMPLETED - completed by Dispositive motions due by April 13, 2026 May 26, 2026 Motions in limine due by July 3, 2026 August 17, 2026 Pretrial Order due by July 3, 2026 August 17, 2026 Trial briefs submitted by July 9, 2026 August 21, 2026 1 For the foregoing reasons, the parties respectfully request that the Court amend the case schedule as proposed in this motion.

3 A proposed order accompanies this stipulation.

4 DATED this 26th day of November, 2025.

5 Respectfully submitted, CHARLES NEIL FLOYD HAGENS BERMAN SOBOL SHAPIRO LLP United States Attorney s/ Alixandria K. Morris s/ Marty D. McLean ALIXANDRIA K. MORRIS, TX No. MARTY D. MCLEAN, WSBA No. 33269 24095373 JESSICA THOMPSON, WSBA No. 48827 9 1301 Second Avenue, Suite 2000 s/ Sean M. Arenson Seattle, Washington 98101 SEAN M. ARENSON, WSBA No. 60465 Phone: 206-623-7292 Assistant United States Attorneys Fax: 206-623-0594 United States Attorney’s Office Email: [email protected] Western District of Washington [email protected] 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 Attorneys for Plaintiffs Phone: 206-553-7970 Fax: 206-553-4073 Email: [email protected] [email protected] Attorneys for United States of America I certify that this memorandum contains 410 words, in compliance with the Local Civil Rules.

1 [PROPOSED] ORDER 2 It is hereby ORDERED that the Parties’ motion is GRANTED. The new pretrial deadlines are as follows: Deadline [Proposed] New Deadline 6 BENCH TRIAL September 28, 2026 Discovery completed by April 28, 2026 9 39.1 Mediation to be completed by COMPLETED Dispositive motions due by May 26, 2026 12 Motions in limine due by August 17, 2026 Pretrial Order due by August 17, 2026 15 Trial briefs submitted by August 21, 2026 17 DATED this 26th of November 2025.

19 A _________________________________ 21 JOHN C. COUGHENOUR United States District Judge