Emerald City Pet Rescue v. Liberty Mutual Insurance Company; Ohio Security...

1 HONORABLE JUDGE JOHN C. COUGHENOUR UNITED STATES DISTRICT COURT 7 FOR THE WESTERN DISTRICT OF WASHINGTON, AT SEATTLE EMERALD CITY PET RESCUE, a || Washington nonprofit corporation, Cause No. 2:24-cv-01843 JCC 10 Plaintiff, STIPULATION AND [PROPOSED] ORDER FOR CONTINUANCE OF 11 vs. CASE SCHEDULE LIBERTY MUTUAL INSURANCE NOTE FOR MOTION CALENDAR: || COMPANY, a for-profit Massachusetts DECEMBER 12, 2025 Company; and OHIO SECURITY || INSURANCE COMPANY, a for-profit Ohio company; and MIDVALE INDEMNITY || COMPANY, a for-profit Wisconsin Company, Defendants.

I. STIPULATION Plaintiff Emerald City Pet Rescue (“ECPR”) and Defendants Liberty Mutual Insurance Company (“Liberty”) and Ohio Security Insurance Company (collectively “Defendants”) jointly request that the Court extend all remaining case schedule deadlines. The Court appointed United States Magistrate Judge Grady Leupold as a settlement judge (ECF # 34), and the parties have scheduled a judicial settlement conference to take place on January 26, 2026. The parties are hopeful that this matter will be settled, and now wish to extend all remaining deadlines to avoid SOHA & LANG, P.S.

STIPULATION AND [PROPGSEB] ORDER FOR CONTINUANCE OF ATTORNEYS AT LAW CASE SCHEDULE ~ | SEATILE, WASHINGTON 8101-2509 USDC WD WA/SEA CAUSE NO. 2:34-ev-0] 843 JCC (206) 624-1800/F ax (206) 624-3585 || additional costs to the parties and for the sake of judicial efficiency. This is the parties’ second request for a case schedule continuance.

3 Currently there is a bench trial scheduled for April 20, 2026. The parties ask that the || bench trial be instead scheduled for June 15, 2026. The parties also ask that all other deadlines || be modified as follows: Event Current New Deadline ; Deadline . December 22, February 16, 8 Discovery completed by 025 026 9 Mediation completed by January 5, 2026 March 2, 2026 10 a. .

Dispositive motions due by January 19, 2026 | March 16, 2026 42 Motions in limine due by April 9, 2026 June 4, 2026 13 Pretrial Order due by April 9, 2026 June 4, 2026 14 . .

Proposed verdict forms, voir dire and jury April 13, 2026 Tune 8, 2026 instructions due by 16 Trial briefs to be submitted by April 15, 2026 June 10, 2026 17 I]. AUTHORITY 18 The parties request this extension of deadlines pursuant to FRCP 6(b)(1)(A), which || provides: 20 When an act may or must be done within a specified time, the court may, for good cause, || extend the time: with or without motion or notice if the court acts, or if a request is made, before || the original time or its extension expires.

SOHA & LANG, P.S.

STIPULATION AND [PROPGSEB] ORDER FOR CONTINUANCE OF ATTORNEYS AT LAW CASE SCHEDULE ~ 2 SEATILE, WASHINGTON 8101-2509 USDC WD WA/SEA CAUSE NO. 2:34-ev-0] 843 JCC (206) 624-1800/F ax (206) 624-3585 1 FRCP 6(b)(1) should be “liberally construed to effectuate the general purpose of seeing 2 cases are tried on the merits.” Ahanchian v. Xenon Pictures, Inc., 624 F.3d 1253, 1258-59 || (9th Cir. 2010) (quoting Rodgers v. Watt, 722 F.2d 456, 459 (9th Cir. 1983)). The phrase “good || cause,” used frequently in our legal system, “means little more than that there is a good reason for... the action proposed to be taken.” California Trout v. Fed. Energy Regulatory Comm’n, 6 F.3d 1003, 1027 (9th Cir. 2009). An extension requested under FRCP 6(b)(1) “normally will || be granted in the absence of bad faith on the part of the party seeking relief or prejudice to the || adverse party.” Id., at 1027 n.1.

9 Here, the parties seek an extension of time to avoid unnecessary litigation costs while the || parties engage in settlement negotiations.

11 STIPULATED TO this 12 day of December, 2025.

12 || BALLARD SPAHR LLP SOHA & LANG, P.S.

13 s/ Steven W. Block _ Steven W. Block, WSBA No. 24299 Paul Rosner, WSBA No. 37146 14 1301 Second Avenue, Suite 2800 Benjamin K. Helford, WSBA No. 46960 Seattle, WA 98101 1325 Fourth Avenue, Suite 940 || Telephone: 206.223.7000 Seattle, WA 98101-2509 [email protected] Telephone: 206-624-1800 || Attorneys for Plaintiff Emerald City Pet [email protected] Rescue Attorneys for Defendants Liberty Mutual 17 Insurance Company and Ohio Security Insurance Company 19 I. ORDER 20 THIS MATTER having come before the Court on the parties’ Stipulation and [Prepesed] 21 Order For Continuance of Case Schedule (Dkt 35) and the Court being fully informed in the || premises, NOW, THEREFORE, SOHA & LANG, P.S.

STIPULATION AND [PROPGSEB] ORDER FOR CONTINUANCE OF ATTORNEYS AT LAW CASE SCHEDULE ~ 3 SEATILE, WASHINGTON 8101-2509 USDC WD WA/SEA CAUSE NO. 2:34-ev-0] 843 JCC (206) 624-1800/F ax (206) 624-3585 1 It is hereby ORDERED, ADJUDGED, AND DECREED that the trial date be updated to || July 13, 2026, and that the following new deadlines are adopted: Event New Deadline 5 Discovery completed by February 16, 2026 6 Mediation completed by March 2, 2026 Dispositive motions due by March 16, 2026 9 Motions in limine due by June 29, 2026 10 Pretrial Order due by June 29, 2026 Proposed verdict forms, voir dire and jury July 3, 2026 instructions due by 13 Trial briefs to be submitted by July 6, 2026 14 Dated this 15th day of December, 2025.

Ac □□ Honorable John C. Coughenour SOHA & LANG, P.S.

STIPULATION AND [PROPGSEB] ORDER FOR CONTINUANCE OF ATTORNEYS AT LAW CASE SCHEDULE ~ 4 SEATILE, WASHINGTON 8101-2509 USDC WD WA/SEA CAUSE NO. 2:34-ev-0] 843 JCC (206) 624-1800/F ax (206) 624-3585