Opinion
2:21-cv-00113-BJR
12-22-2021
D.S. by and through her next friend TARA URS; et al., Plaintiffs, v. WASHINGTON STATE DEPARTMENT OF CHILDREN, YOUTH, AND FAMILIES; et al., Defendants.
PLAINTIFFS' COUNSEL SUSAN KAS, WSBA No. 36592, CHRISTOPHER CARNEY, Carney Gillespie PLLC ROBERT W. FERGUSON Attorney General DANIEL J. JUDGE, WSBA No. 17392, WILLIAM MCGINTY, WSBA No. 41868, JAMES M. RICHARDSON III, WSBA No. 45095 Assistant Attorneys General Attorneys for Defendants LEECIA WELCH, WSBA No. 26590 POONAM JUNEJA, CA Bar ID No. 300848, admitted pro hac vice FREYA PITTS, CA Bar ID No. 295878, admitted pro hac vice JEAN STROUT, CA RLSA No. 804338, admitted pro hac vice National Center for Youth Law LAURA LIN, CA Bar ID No. 281542, admitted pro hac vice ELIZABETH DOUGLAS, CA Bar ID No. 331031, admitted pro hac vice ALEXANDER S. GORIN, WSBA No. 53538 Munger, Tolles & Olson, LLP Attorneys for Plaintiffs
PLAINTIFFS' COUNSEL SUSAN KAS, WSBA No. 36592, CHRISTOPHER CARNEY, Carney Gillespie PLLC
ROBERT W. FERGUSON Attorney General DANIEL J. JUDGE, WSBA No. 17392, WILLIAM MCGINTY, WSBA No. 41868, JAMES M. RICHARDSON III, WSBA No. 45095 Assistant Attorneys General Attorneys for Defendants
LEECIA WELCH, WSBA No. 26590
POONAM JUNEJA, CA Bar ID No.
300848, admitted pro hac viceFREYA PITTS, CA Bar ID No. 295878,
admitted pro hac vice
JEAN STROUT, CA RLSA No. 804338,
admitted pro hac vice
National Center for Youth Law
LAURA LIN, CA Bar ID No. 281542,
admitted pro hac vice
ELIZABETH DOUGLAS, CA Bar ID
No. 331031, admitted pro hac vice
ALEXANDER S. GORIN,
WSBA No. 53538
Munger, Tolles & Olson, LLP
Attorneys for Plaintiffs
STIPULATION AND ORDER REGARDING AMENDMENT TO SCHEDULING ORDER
BARBARA J. ROTHSTEIN UNITED STATES DISTRICT JUDGE
The Honorable Barbara J. Rothstein
I.STIPULATION
The parties, by and through their respective attorneys of record, hereby stipulate to the following:
1. The parties agree that the pretrial schedule should be amended to accommodate the parties' mediation of this matter occurring during the last six months and continuing.
2. The parties agree that general pretrial dates be extended by approximately 90 days and that the dates specific to trial be extended by approximately 120 days as set forth below.
3. The parties agree that the current pretrial schedule (Dkts. #22, 61, 67, and 75) should be amended as follows:
a. Reports from expert witnesses under Fed.R.Civ.P. 26(a)(2) are to be served on or by April 7, 2022;
b. Initial deadline for completed discovery is May 9, 2022;
c. All dispositive motions are to be filed on or by June 10, 2022;
d. Opposition for dispositive motions (per Dkt. #16 briefing schedule) is to be filed on or by July 1, 2022; and e. Replies for dispositive motions (per Dkt. #16 briefing schedule) are to be filed on or by July 15, 2022.
4. The parties agree that the current scheduling of trial-related dates (Dkts. #22, 61 and 67) should be amended by 120 days as follows:
a. Motions in Limine shall be filed by August 30, 2022;
b. The Joint Pretrial Statement shall be filed by September 6, 2022;
c. The Pretrial Conference shall be set for September 20, 2022;
d. The Trial (sixteen days) shall be set for October 4, 2022 or the next available date.
5. The parties agree that this Court should enter an order that approves and adopts this stipulation.
RESPECTFULLY SUBMITTED this 17th day of December, 2021.
II. ORDER
IT IS HEREBY ORDERED that:
1. The stipulation of the parties is APPROVED AND ADOPTED as follows:
2. The pretrial schedule (Dkts. #22, 61, 67, and 75) is AMENDED as follows:
a. Reports from expert witnesses under Fed.R.Civ.P. 26(a)(2) shall be served on or by April 7, 2022;
b. The initial deadline for completed discovery is May 9, 2022;
c. All dispositive motions shall be filed on or by June 10, 2022;
d. Opposition for dispositive motions (per Dkt. #16 briefing schedule) shall be filed on or by July 1, 2022; and e. Replies for dispositive motions (per Dkt. #16 briefing schedule) shall be filed on or by July 15, 2022.
3. The schedule of trial-related dates (Dkts. #22, 61 and 67) is AMENDED as follows:
a. Motions in Limine shall be filed by August 30, 2022;
b. The Joint Pretrial Statement shall be filed by September 6, 2022;
c. The Pretrial Conference shall be set for September 20, 2022. d. The Trial (sixteen days) shall be set for October 4, 2022.
The Clerk is directed to forward copies of this Order to the parties in this matter.