Opinion
2:21-cv-00823-JLR
12-09-2021
JOSEPH ROGERS, DEBRA JONES STEVENSON, FRANK GARRIDO, TAYLOR ARMIGER, and GWENDOLYN THOMPSON, on behalf of themselves and all others similarly situated, Plaintiffs, v. ASSURANCE IQ, LLC, Defendant.
Samuel J. Strauss, WSBA #46971 TURKE & STRAUSS LLP Anthony Paronich, Admitted Pro Hac Vice PARONICH LAW, P.C. John Du Wors NEWMAN DU WORS LLP Attorneys for Defendant Timothy J. Sostrin, Admitted Pro Hac Vice KEOGH LAW, LTD. Attorneys for Plaintiffs
Samuel J. Strauss, WSBA #46971
TURKE & STRAUSS LLP
Anthony Paronich, Admitted Pro Hac Vice
PARONICH LAW, P.C.
John Du Wors
NEWMAN DU WORS LLP
Attorneys for Defendant
Timothy J. Sostrin, Admitted Pro Hac Vice
KEOGH LAW, LTD.
Attorneys for Plaintiffs
STIPULATED MOTION AND [PROPOSED] ORDER TO EXTEND DEADLINES
JAMES L. ROBART United States District Judge
THE HONORABLE JAMES L. ROBART Plaintiffs Joseph Rogers, Debra Jones Stevenson, Frank Garrido, Taylor Armiger, and Gwendolyn Thompson ("Plaintiffs") and Defendant Assurance IQ, LLC ("Defendant") (together with Plaintiffs, the "Parties") hereby jointly move the Court for an order extending certain class certification deadlines.
On September 24, 2021, the Court issued a Rule 16(b) and Rule 23(d)(2) Scheduling Order Regarding Class Certification Motion. Dkt. No. 20. On October 12, 2021, Kelsey Smith filed a motion seeking leave to amend her complaint to add four new individuals with similar claims against Defendant. Dkt. No. 26. After the filing of Kelsey Smith's motion, the Parties agreed to stipulate to the filing of an amended complaint adding five new individuals making similar claims against Defendant and removing Kelsey Smith as a plaintiff. On November 3, 2021, the Parties filed their stipulated motion for leave to amend, which this Court granted on November 4, 2021. Dkt. Nos. 33, 34. Plaintiffs filed their amended complaint on November 4, 2021, and Defendant promptly answer on November 18, 2021. Dkt. Nos. 35, 36.
The Parties jointly request an extension of the class certification deadlines in order for the Parties to investigate the new Plaintiffs' claims, conduct discovery, and develop their positions on class certification, including the expert discovery necessary for that motion. The Parties have met and conferred and seek modification of the class certification deadlines as follows:
Initial Pretrial Scheduling Order (Dkt. No. 20)
Parties' Stipulated and Requested Modification
Deadline for Completion of Fact and Expert Discovery
November 12, 2021
August 3, 2022
Deadline for Plaintiffs to File Motion for Class Certification (Briefing deadlines shall conform with Local Rule 7)
December 14, 2021
August 30, 2022
WHEREFORE, the Parties respectfully request an Order modifying the current class certification deadlines as describe herein.
ORDER
IT IS SO ORDERED.