Opinion
2:22-cv-00509
02-17-2023
FOSTER GARVEY PC Patrick J. Schneider P. Stephen DiJulio, Andrea L. Bradford Attorneys for Plaintiff North Bend Associates, LLC KEATING, BUCKLIN & MCCORMACK, INC., P.S. Michael C. Walter Jeremy W. Culumber Attorneys for City of North Bend
FOSTER GARVEY PC
Patrick J. Schneider
P. Stephen DiJulio,
Andrea L. Bradford
Attorneys for Plaintiff North Bend Associates, LLC
KEATING, BUCKLIN & MCCORMACK, INC., P.S.
Michael C. Walter
Jeremy W. Culumber
Attorneys for City of North Bend
JOINT STIPULATION TO CONTINUE DISCOVERY CUTOFF
NOTED FOR CONSIDERATION
RICARDO S. MARTINEZ, UNITED STATES DISTRICT JUDGE
I. INTRODUCTION
The parties agree there is good cause to continue the discovery cutoff by three weeks to facilitate the conclusion of discovery in this matter. The parties have worked together in good faith to arrive at this agreement for a short extension to the discovery cutoff. This continuance will not impact the remaining dates on the case schedule and is consistent with the Court's Order Denying Motion to Extend Certain Deadlines. Dkt. 20 at 4.
II. STATEMENT OF FACTS
The existing discovery cutoff in this case is February 27, 2023. Dkt. 13. The facts regarding discovery in this matter have been previously presented to this Court in the briefing on Defendant's Motion to Continue Case Schedule. Dkt. 14; Dkt. 16; Dkt. 19. In the Court's order denying the motion, the Court noted “To the extent the parties would benefit from a short extension of just the discovery deadline the Court expects the parties to consider that possibility in good faith and to submit a stipulated motion.” Dkt. 20 at 4. Consistent with the Court's order, the parties have worked together in good faith to agree to the short extension sought in this stipulation.
III. ARGUMENT
The court's case schedule may be modified “for good cause and with the judge's consent.” LCR 16(b)(6). Since the parties briefed the Motion to Continue, the parties have worked cooperatively and in good faith to complete discovery in this matter. In order to complete the remaining document productions and depositions in this matter, the parties agree that good cause exists to extend the discovery cutoff by three weeks. This short extension will not impact the remaining dates on the case schedule, including the dispositive motion deadline and the trial date in this matter. This short extension is consistent with the Court's prior Order Denying Motion for Extension of Certain Deadlines. Dkt. 20 at 4.
IV. CONCLUSION
The parties jointly request a continuance of the February 27, 2023 discovery cutoff to March 21, 2023.
ORDER
IT IS SO ORDERED.