Opinion
3:22-cv-05618-MLP
03-03-2023
WILLIAM SAVOIE, Plaintiff, v. GULICK TRUCKING, INC., Defendant.
MBE LAW GROUP PLLC Lisa A. Burke, WSBA No. 42859 Attorneys for Plaintiff BULLARD LAW Ed Choi, OSB No. 135673 Attorneys for Defendants
MBE LAW GROUP PLLC
Lisa A. Burke, WSBA No. 42859
Attorneys for Plaintiff
BULLARD LAW
Ed Choi, OSB No. 135673
Attorneys for Defendants
STIPULATED MOTION AND PROPOSED ORDER EXTENDING TRIAL DATE AND RELATED DEADLINES
STIPULATED MOTION EXTENDING TRIAL DATE AND OTHER RELATED DEADLINES
On November 4, 2022 this Court entered a Minute Order (Dkt. 14) setting a trial date of September 25, 2023 for this matter, as well as a summary judgment deadline of May 22, 2023 and other related dates.
The parties are cooperatively and diligently working on discovery, including review and production of electronically stored data. The parties are also cooperatively and diligently working on the scheduling of depositions; however, those depositions cannot occur prior to the completion of written discovery, which the parties need more time to complete. Counsel for Plaintiff similarly has a two-week jury trial scheduled to start on April 3, 2023 (No: 2:20-cv-01775-RSL), which has created some unavailability of counsel.
So that the parties have sufficient time to complete written discovery and depositions, as well as ADR, the parties have agreed to respectfully request that the Court postpone the trial date and related dates in this case. The parties agree on the below schedule for proposed new dates:
| Event | Deadline set on November 4, 2022 | Requested New Deadline |
| Reports of expert witnesses under FRCP 26(a)(2) due | March 6, 2023 | June 5, 2023 |
| All motions related to discovery must be FILED by this date and noted for consideration no later than the third Friday thereafter (see LCR7(d)) | March 20, 2023 | June 19, 2023 |
| Rebuttal expert disclosures under FRCP 26(a)(2) due | April 6, 2023 | July 6, 2023 |
| Discovery to be completed by | April 20, 2023 | July 20, 2023 |
| All dispositive motions must be FILED by | May 22, 2023 | August 21, 2023 |
| Mediation per LCR 39.1 held no later than | July 21, 2023 | September 22, 2023 |
| Motions in limine should be FILED by and NOTED on the motions calendar no later than the third Friday thereafter, but no later than the Friday before any scheduled pretrial conference | August 21, 2023 | November 13, 2023 |
| Agreed pretrial order LODGED with the court by | September 5, 2023 | December 4, 2023 |
| Pretrial conference will be HELD on TBD TBD Trial briefs, proposed voir dire & jury instructions due | September 11, 2023 | December 11, 2023 |
| JURY TRIAL set for | September 25, 2023 | December 18, 2023 January 22, 2024 |
The parties respectfully request an extension of all dates as set forth above, or a further extension as may be convenient for the Court's trial calendar.
[PROPOSED] ORDER
IT IS SO ORDERED.