Jared Dion v. Imperva, Inc.

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT TACOMA JARED DION, an individual, 10 Case No.: 3:24-cv-05795-JHC Plaintiff, 11 STIPULATED MOTION TO v. CONTINUE TRIAL DATE AND ALL PRETRIAL DEADLINES AND IMPERVA, INC., a Delaware corporation, ORDER Defendant.

NOTING DATE: December 1, 2025 15 STIPULATION 16 Plaintiff Jared Dion and Defendant Imperva, Inc. (collectively, the “Parties”) jointly submit this Stipulated Motion to Continue Trial Date and All Pretrial Deadlines. Specifically, the Parties respectfully request that the trial date and all pretrial deadlines be extended by 90 days. A continuance will allow the Parties sufficient time to continue their exchange of extensive discovery and effectively litigate this matter. The Parties represent that there is good cause for a continuance.

22 I. FACTS RELEVANT TO THIS MOTION 23 Plaintiff filed his Complaint with this Court on September 17, 2024 (ECF No. 1) and subsequently filed an Amended Complaint on May 7, 2025 (ECF No. 19). Trial is set for June 1, 2026, and the discovery cutoff is January 2, 2026. See Order Setting Trial Date and Related Dates dated June 4, 2025 (ECF No. 22). To date, the Parties have exchanged discovery but in light of upcoming deadlines the Parties believe additional time in the case schedule will be necessary.

3 Specifically, Defendant is working diligently to locate a substantial number of documents, which has taken a considerable amount of time due to its IT department being located in another country. Additionally, both Plaintiff and Defendant need time to take adequate depositions, however, they are facing tight deadlines with the upcoming holidays. Counsel has worked to complete discovery but need additional time due to scheduling issues which has limited their ability to conduct depositions and final discovery prior to its close on January 2, 2026.

9 The Parties believe that an extension of the below deadlines and the trial date will allow the Parties to complete discovery and effectively litigate this matter. This is the first time the Parties have requested the Court continue the scheduled dates. The proposed new deadlines are outlined below: Event Current Deadline Proposed Deadline Bench Trial (6-8 days) June 1, 2026 October 26, 2026 Disclosure of expert testimony under November 3, 2025 February 2, 2026 FRCP 26(a)(2) All motions related to discovery December 3, 2025 March 3, 2026 Discovery completed January 2, 2026 April 2, 2026 All dispositive motions and motions February 2, 2026 May 4, 2026 challenging expert witness testimony Settlement conference April 2, 2026 July 1, 2026 Motions in Limine April 20, 2026 July 20, 2026 Agreed pretrial order May 11, 2026 August 10, 2026 Deposition Designations May 13, 2026 August 11, 2026 Pretrial conference May 18, 2026 August 17, 2026 Trial briefs, proposed findings of fact May 26, 2026 August 24, 2026 and conclusions of law 1 II. ARGUMENT 2 The Court may extend the case schedule where good cause exists. Fed. R. Civ. 3 P. 16(b)(4); LCR 16(b)(5); Johnson v. Mammoth Recreations, Inc., 975 F.2d 604 (9th Cir. 1992). In this case, the Parties jointly assert that good cause exists, and they agree that a continuance is necessary to allow the Parties sufficient time to complete all necessary discovery around their conflicts especially with the upcoming holidays. The Parties further believe good cause exists for an extension on all remaining deadlines and the trial date, to allow the Parties adequate time to engage in dispositive motions, where needed, and prepare for trial.

9 Additionally, this would allow the Parties additional time to engage in settlement discussions without a pressing trial date.

11 III. CONCLUSION 12 For the foregoing reasons, the Parties respectfully move the Court to continue the trial date and pretrial deadlines by ninety (90) days.

14 STIPULATED AND AGREED TO by the Parties as of December 1, 2025.

15 s/ Mark K. Davis (with consent) s/ Clarence M. Belnavis Mark K. Davis, WSBA No. 38713 Clarence M. Belnavis, WSBA No. 36681 DICKERSON DAVIS AHMED PLLC Christina M. Shin, WSBA No. 56151 Second Avenue S. Ste. 190 FISHER & PHILLIPS LLP Edmonds, WA 98020 1700 Seventh Avenue, Suite 2200 Phone: 425.776.1352 Seattle, WA 98101 Email: [email protected] Phone: 206.682.2308 19 Email: [email protected] Attorney for Plaintiff [email protected] Attorneys for Defendant 1 ORDER 2 Based on the foregoing, the Court CONTINUES trial in this matter to October 26, 2026.

3 || The Court is not inclined to grant another trial continuance. The Court DIRECTS the Clerk to || issue a case scheduling order.

5 ORDERED this 2nd day of December, 2025. < Job. 4, Chas 8 JOHN H. CHUN 9 United States District Judge 1] STIPULATED MOTION TO CONTINUE TRIAL DATE AND ATT PRETRIAT DEADT INES AND ORDER — PACE