Jeanne Suchodolski v. John C. Phelan, Secretary of the Navy

1 The Honorable Jamal N. Whitehead 7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE JEANNE SUCHODOLSKI, Case No. 2:24-cv-00686-JNW Plaintiff, STIPULATED MOTION AND 11 ORDER FOR EXTENSION OF TRIAL v. DATE AND RELATED DATES JOHN C. PHELAN, Secretary of the Navy, Noted for Consideration: 13 January 16, 2026 Defendant.

15 Pursuant to the Court’s Order (Dkt. 38), the parties hereby jointly submit and STIPULATE and AGREE they need more time and respectfully request to extend the following deadlines, including the trial date. 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).

19 The decision to modify a scheduling order lies within the broad discretion of the district court.

20 Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 607 (9th Cir. 1992).

21 Good cause exists to amend the following deadlines in the Order for the reasons previously set forth in the parties’ Motion for Extension of the Case Schedule (Dkt. 35), such being that one of the United States’ counsel, is currently on parental leave, with an anticipated return date of January 21, 2025. Additionally, the U.S. Attorney’s Office has experienced an unprecedented increase in emergency motions requiring immediate attention, further supporting the need for the requested extensions. Plaintiff’s counsel will also be unavailable with trial and will require additional time beyond the corresponding extension for their response.

4 Accordingly, the parties jointly and respectfully request that the Court extend the following deadlines in the Order as set forth below: 6 Case Event Current Deadline Proposed Deadline (ECF No. 36 & 38) TBD [A date convenient for 8 JURY TRIAL begins May 26, 2026 the Court not earlier than August 17, 2026] Defendant’s dispositive motions1 must be filed by and Parties motions challenging January 30, 2026 February 25, 2026 expert witness testimony must be filed by (see LCR 7(d)) Plaintiff’s Opposition brief to Defendant’s dispositive February 19, 2026 April 1, 2026 motions must be filed by Defendant’s Reply brief must March 5, 2026 April 15, 2026 be filed by All motions in limine must be April 6, 2026 July 10, 2026 filed by Deposition Designations must be submitted to the court (not filed on April 27, 2026 July 14, 2026 CM/ECF) by: (see LCR 32(e)) Agreed pretrial order due April 27, 2026 July 27, 2026 Trial briefs, proposed findings of fact and conclusions of law May 4, 2026 July 28, 2026 by Pretrial conference May 11, 2026 TBD Pursuant to section 5.8 of this Court’s civil chambers procedures, parties have conferred regarding cross motions for summary judgment and whether a proposed briefing schedule is needed. Parties have confirmed that while 1 For the foregoing reasons, the parties respectfully request that the Court amend the specific deadlines proposed in this motion.

3 A proposed order accompanies this motion.

4 DATED this 16th day of January, 2026.

5 Respectfully submitted, CHARLES NEIL FLOYD ALAN LESCHT AND ASSOCIATES, P.C.

United States Attorney s/ Alixandria K. Morris s/ Victoria L. Watson ALIXANDRIA K. MORRIS, TX No. 24095373 VICTORIA L. WATSON* s/ Sean M. Arenson s/ Kathryn Kelly SEAN M. ARENSON, WSBA No. 60456 KATHRYN KELLY* Assistant United States Attorneys United States Attorney’s Office s/ Ari M. Wilkenfeld Western District of Washington ARI M. WILKENFELD* Stewart Street, Suite 5220 1825 K Street, NW, Suite 750 Seattle, Washington 98101-1271 Washington, DC 20006 Phone: 206-553-7970 Email: [email protected] Fax: 206-553-4073 Email: [email protected] Email: [email protected] Email: [email protected] Email: [email protected] *Admitted Pro Hac Vice Attorneys for Defendant I certify this memorandum contains 434 words, in compliance with Local Civil Rules. HKM EMPLOYMENT ATTORNEYS LLP 17 /s/Daniel Kalish DANIEL KALISH, WSBA No. 65815 18 600 Stewart Street, Suite 901 Seattle, Washington 98101 19 Phone: 206-826-5354 Fax: 206-826-5354 20 Email: [email protected] 21 Attorneys for Plaintiff 1 ORDER 2 The Court having reviewed the pleadings and materials in this case, it is hereby 3 ORDERED that the Parties’ motion is GRANTED. The new deadlines are as follows: Deadline New Deadline 6 JURY TRIAL begins October 13, 2026 Defendant’s dispositive motions must be filed by and Parties motions challengin 8 y ging expert witness testimony must be filed by February 25, 2026 9 (see LCR 7(d)) Plaintiff's Opposition brief to Defendant’s .

10 dispositive motions must be filed by April 1, 2026 ll Defendant’s Reply brief must be filed by April 15, 2026 All motions in limine must be filed by July 10, 2026 Deposition Designations must be 13 submitted to the court (not filed on July 14, 2026 CM/ECF) by: (see LCR 32(e)) Agreed pretrial order due July 27, 2026 15 4; Trial briets, proposed findings of fact and uly 28, 2026 16 conclusions of law by 19 DATED this 4th day of February, 2026.

MAL N. WHITEHEAD 22 United States District Judge STIPULATED MOTION AND ORDER FOR UNITED STATES ATTORNEY EXTENSION OF TRIAL DATE AND RELATED DATES 700 Stewart Street. Suite 5220