Opinion
2:23-cv-00630-JLR
07-06-2023
ANNA PATRICK, DOUGLAS MORRILL, ROSEANNE MORRILL, LEISA GARRETT, ROBERT NIXON, SAMANTHA NIXON, DAVID BOTTONFIELD, ROSEMARIE BOTTONFIELD, TASHA RYAN, ROGELIO VARGAS, MARILYN DEWEY, PETER ROLLINS, RACHAEL ROLLINS, KATRINA BENNY, SARA ERICKSON, GREG LARSON, and JAMES KING, individually and on behalf of all others similarly situated, Plaintiffs, v. DAVID L. RAMSEY, III, individually; HAPPY HOUR MEDIA GROUP, LLC, a Washington limited liability company; THE LAMPO GROUP, LLC, a Tennessee limited liability company, Defendants.
ALBERT LAW PLLC Gregory W Albert, WSBA #42673 Jonah L Ohm Campbell, WSBA #55701 Tallman Harlow Trask, IV, WSBA #60280 FRIEDMAN RUBIN PLLC (SEATTLE- DOWNTOWN) Roger S. Davidheiser, WSBA #18638 Attorneys for Plaintiffs MORGAN, LEWIS & BOCKIUS LLP Patricia A. Eakes, WSBA No. 18888 Damon C. Elder, WSBA No. 46754 Tyler Weaver, WSBA No. 29413 Andrew DeCarlow, WSBA No. 54471 Attorneys for Defendants David L. Ramsey, III and The Lampo Group, LLC CORR CRONIN LLP Jack Lovejoy Attorney for Defendant Happy Hour Media Group, LLC
ALBERT LAW PLLC
Gregory W Albert, WSBA #42673
Jonah L Ohm Campbell, WSBA #55701
Tallman Harlow Trask, IV, WSBA #60280
FRIEDMAN RUBIN PLLC (SEATTLE- DOWNTOWN)
Roger S. Davidheiser, WSBA #18638
Attorneys for Plaintiffs
MORGAN, LEWIS & BOCKIUS LLP
Patricia A. Eakes, WSBA No. 18888
Damon C. Elder, WSBA No. 46754
Tyler Weaver, WSBA No. 29413
Andrew DeCarlow, WSBA No. 54471
Attorneys for Defendants David L. Ramsey, III and The Lampo Group, LLC
CORR CRONIN LLP
Jack Lovejoy
Attorney for Defendant Happy Hour Media Group, LLC
STIPULATION AND [PROPOSED] ORDER REGARDING DEADLINES TO RESPOND TO COMPLAINT AND RELATED BRIEFING SCHEDULES
HONORABLE JAMES L. ROBART UNITED STATES DISTRICT JUDGE
WHEREAS, Defendants David L. Ramsey III and The Lampo Group, LLC waived service of process on May 25, 2023, and Defendant Happy Hour Media Group, LLC waived service of process on July 6, 2023, WHEREAS, under the Federal Rules of Civil Procedure, the current deadlines for Defendants to answer or otherwise respond to the Complaint are July 24, 2023, and August 14, 2023, respectively, WHEREAS, each of the Defendants anticipate that they will respond to the Complaint by filing motions to dismiss pursuant to Fed.R.Civ.P. 12, and
WHEREAS, the parties have met and conferred regarding the motions to dismiss and an appropriate briefing schedule.
THEREFORE, in order to provide a single, coordinated schedule for briefing Defendants' anticipated motions to dismiss, and to accommodate counsels' schedules on both sides, the parties have agreed to the following deadlines and ask that the Court enter an Order adopting them:
Date by which any motions to dismiss will be due: August 10, 2023
Date by which oppositions will be due: September 7, 2023
Date on which motions will be noted and reply briefs will be due: September 15, 2023
In addition to the above, one or more Defendants anticipate they will file a motion to stay discovery and to stay issuance of a case schedule pending the resolution of the motions to dismiss. The parties stipulate and agree that the motion to stay should be filed on August 10, 2023. The parties further agree that while any party may issue written discovery prior to August 10, no party shall be required to respond substantively to discovery until the Court resolves the motion to stay. This stipulation is without prejudice to any party's position regarding the merits of a stay.
[PROPOSED] ORDER
IT IS SO ORDERED.