John Taylor v. Hartford Casualty Insurance Company

5 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 6 AT SEATTLE JOHN TAYLOR, No. 2:25-cv-00460-RSM 8 Plaintiff, STIPULATED MOTION AND ORDER TO CONTINUE TRIAL DATE AND ISSUE 9 vs. AMENDED CASE SCHEDULE HARTFORD CASUALTY INSURANCE COMPANY, a foreign insurance company, Defendant.

13 I. STIPULATION AND RELIEF REQUESTED 14 Pursuant to LCR 10(g) and 16(b)(6), the parties respectfully request the Court continue the current trial date and all pre-trial deadlines by 120 days and issue a new Scheduling Order reflecting the same. The parties have conferred, and this motion is stipulated.

17 Good cause exists to modify the case schedule. The parties are working together to resolve outstanding discovery issues and additional time is needed to complete these issues in order to properly prepare experts for disclosures. Additionally, the parties are discussing resolution and seek additional time in order to allow meaningful discussions without increased litigation costs and the constraints they impose. The parties have not yet sought an extension of any deadlines in this case and the parties agree an extension is needed here.

Stipulated Motion and Order – 1 1 II. STATEMENT OF FACTS 2 Due to technical issues, and schedule constraints Defendant has only recently provided certain pertinent discovery to allow the parties to provide proper expert reports. Additionally, Defendant has pursued medical records from Plaintiff, but believe some are still outstanding which would be relevant to any expert opinions in this case. Further, the parties are focused at this time on resolution, without incurring additional litigation costs in order to promote meaningful settlement negotiations. The parties are hopeful that the remaining issues in the case can be resolved by negotiation. The parties are jointly seeking a continuance in this matter of all deadlines as follows: 10 Description Current Date Proposed Date Disclosure of expert testimony under FRCP 26(a)(2) 12/10/25 04/09/26 Deadline for filing motions related to discovery. Any 01/09/26 05/06/26 such motions shall be noted for consideration pursuant to LCR 7(d)(3) Discovery completed by 02/09/26 06/09/26 All dispositive motions must be filed by and noted on 03/10/26 07/08/26 the motion calendar no later than 28 days thereafter (see 14 LCR 7(d)) Mediation per LCR 39.1(c)(3), if requested by the 04/24/26 08/22/26 parties, held no later than All motions in limine must be filed by and noted on the 05/11/26 09/08/26 motion calendar no later than 21 days thereafter Agreed pretrial order due 05/27/26 09/24/26 Pretrial conference to be scheduled by the Court.

Trial briefs, proposed voir dire questions, jury 06/03/26 10/01/26 instructions, neutral statement of the case, and trial exhibits due Jury Trial Date (5-7 days) 06/08/26 10/06/26 III. ARGUMENT A. Applicable Legal Standard “A [case] schedule may be modified only for good cause and with the judge’s consent.”

Stipulated Motion and Order – 2 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).

5 B. Good Cause Exists to Modify the Trial Date and Case Schedule 6 Good cause exists to amend the trial deadlines in this matter as outlined above and in the introduction.

8 IV. ORDER 9 After consideration of the Stipulated Motion to Amend Case Schedule, and the Court being fully advised on the premises, it is hereby ORDERED that the Parties’ Stipulated Motion is hereby GRANTED.

12 IT IS FURTHER ORDERED that the current case schedule deadlines are moved forward 120 days in this matter and will be continued to October 6, 2026, and an Order Amending Case Schedule will be issued by the Court.

15 Dated: December 10, 2025.

16 A RICARDO S. MARTINEZ 18 UNITED STATES DISTRICT JUDGE

Stipulated Motion and Order – 3