Opinion
23-2-CV-00269 JLR
04-02-2024
DOROTHY TRUEBLOOD, Plaintiff, v. VALLEY CITIES COUNSELING AND CONSULTATION, Defendant.
PACIFIC JUSTICE INSTITUTE: Tracy Tribbett, WSBA #35922 Attorney for Plaintiff Laura T. Morse, WSBA No. 34532 Attorneys for Defendant Valley Cities Counseling and Consultation
PACIFIC JUSTICE INSTITUTE: Tracy Tribbett, WSBA #35922 Attorney for Plaintiff
Laura T. Morse, WSBA No. 34532 Attorneys for Defendant Valley Cities Counseling and Consultation
STIPULATED MOTION AND [PROPOSED] ORDER TO EXTEND DEADLINE FOR FILING OF MOTION FOR SUMMARY JUDGMENT AND STRIKE TRIAL DATES
Honorable Judge James L. Robart Judge
I. STIPULATED MOTION
The parties, by and through their undersigned counsel of record, hereby stipulate to and jointly request pursuant to LCR 4(d) to strike the trial date in the above captioned matter and for an extension of the dispositive motion deadlines set forth in the Order Setting Civil Case Schedule. The operative deadline to file a dispositive motion is April 30, 2024. The parties have conferred and each is intending to file a dispositive motion. The parties will stipulate to the material facts, and intend to stipulate to issues. No party has previously requested an extension of the trial date or pre-trial deadlines. Specifically, the parties request that the Court set the following deadline for filing dispositive motion(s):
June 30, 2024.
The parties have worked together regarding discovery and all discovery has been completed by the required date of April 1, 2024. However, the depositions were taken the end of March and the extension of time to file the Rule 56(c) Summary Judgment Motions will allow the parties additional time to receive and review the transcripts, determine material facts and issues, and submit the briefing.
The parties desire to resolve this case by dispositive motion practice, and do not intend to move forward to trial.
Good cause exists for this extension. Due to various scheduling conflicts, the parties have agreed to the above-mentioned deadline, and striking of further trial-dates. This agreed upon extension will provide the parties with sufficient time to review discovery and submit their motions. The parties respectfully request that the Court grant this stipulated motion.
II. ORDER
Based on the stipulation of counsel for the parties, IT IS HEREBY ORDERED that the trial date and all other dates in the Minute Order Setting Trial Deadlines and Related Dates be stricken and that the deadline for filing of dispositive motion(s) under Rule 56(c) be moved to June 28, 2024.*
*Because the parties' proposed date of June 30, 2024 falls on a Sunday, the court sets the dispositive motions deadline for Friday, June 28, 2024.