R.K. v. Corporation of the President of the Church of Jesus Christ of Latter-Day Saints, et al

Filing 35

DECLARATION of Thomas D. Frey filed by Defendants LDS Social Services, Corporation of the President of the Church of Jesus Christ of Latter-Day Saints re 34 Agreed MOTION to Amend 23 Scheduling Order,, (Frey, Thomas)

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R.K. v. Corporation of the President of the Church of Jesus Christ of Latter-Day Saints, et al Doc. 35 Case 2:04-cv-02338-RSM Document 35 Filed 05/02/2005 Page 1 of 3 1 2 3 4 5 6 7 8 9 10 v. 11 12 13 14 15 Defendants. 16 17 THOMAS D. FREY declares as follows: 18 1. 19 THE CORPORATION OF THE PRESIDENT OF THE CHURCH OF JESUS CHRIST OF LATTER-DAY SAINTS, a Utah corporation sole, a/k/a "MORMON CHURCH"; LDS SOCIAL SERVICES a/k/a LDS FAMILY SERVICES, a Utah corporation, The Honorable Ricardo Martinez UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE KENNETH FLEMING and JOHN DOE, Plaintiffs, DECLARATION OF THOMAS D. FREY IN SUPPORT OF AGREED MOTION TO AMEND CASE SCHEDULE RE MEDIATION DEADLINE Noted for: May 11, 2005 No. 04-2338 RSM I am one of the attorneys for the defendants Corporation of the President of Church of Jesus Christ of Latter-Day Saints and LDS Family Services. I am over the 20 age of 18 years and am competent to testify as to the matters contained herein. 21 22 23 FREY DECLARATION IN SUPPORT OF AGREED MOTION TO AMEND CASE SCHEDULE RE MEDIATION DEADLINE -- 1 No. CV04-2338 RSM M:\Clients\7566\25226\Pleadings\PLD Amend Case Sched - Decl TDF.doc PROFESSIONAL CORPORATION 601 Union Street, Suite 3100 Seattle WA 98101.1374 TEL 206.623.9900 FAX 206.624.6885 Dockets.Justia.com Case 2:04-cv-02338-RSM Document 35 Filed 05/02/2005 Page 2 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 2. The Case Schedule herein has set the mandatory mediation to be held no later than May 27, 2005. A true and correct copy of the Case Schedule is attached hereto at page 3. 3. The date for the completion of all discovery in this case has been set for October 31, 2005. 4. The parties have commenced written discovery and will not be able to complete all written discovery and depositions prior to the May 27, 2005 mediation deadline. 5. Without the information which will be learned from completing the discovery in this case, early mediation will not be meaningful or fruitful. 5. The parties herein have met and conferred, and it has been agreed that it would be in the best interest of resolution of this case to extend the mediation deadline. 6. The parties have agreed that any time from December 1, 2005 to December 16, 2005, they will be available and prepared to engage in meaningful mediation of this matter. I declare under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct. Executed this 2nd day of May, 2005, at Seattle, Washington. s/ Thomas D. Frey Thomas D. Frey, WSBA #1908 E-mail: tfrey@staffordfrey.com FREY DECLARATION IN SUPPORT OF AGREED MOTION TO AMEND CASE SCHEDULE RE MEDIATION DEADLINE -- 2 No. CV04-2338 RSM M:\Clients\7566\25226\Pleadings\PLD Amend Case Sched - Decl TDF.doc PROFESSIONAL CORPORATION 601 Union Street, Suite 3100 Seattle WA 98101.1374 TEL 206.623.9900 FAX 206.624.6885 Case 2:04-cv-02338-RSM Document 35 Filed 05/02/2005 Page 3 of 3 1 2 CERTIFICATE OF SERVICE I certify that on the date noted below I electronically filed the Declaration of 3 Thomas D. Frey in Support of Agreed Motion to Amend Case Schedule Re 4 Mediation Deadline using the CM/ECF system which will send notification of such filing 5 to the following persons: 6 7 8 9 10 11 12 13 14 15 16 /s/Thomas D. Frey 17 18 19 20 21 22 23 FREY DECLARATION IN SUPPORT OF AGREED MOTION TO AMEND CASE SCHEDULE RE MEDIATION DEADLINE -- 3 No. CV04-2338 RSM M:\Clients\7566\25226\Pleadings\PLD Amend Case Sched - Decl TDF.doc Michael T. Pfau Gordon Thomas Honeywell Malanca Peterson & Daheim 600 University Street, Suite 2100 Seattle, WA 98101-4185 Email: mpfau@gth-law.com Attorneys for Plaintiffs Timothy D. Kosnoff Law Offices of Timothy D. Kosnoff 600 University Street, Suite 2100 Seattle, WA 98101 Email: timkosnoff@comcast.net Attorneys for Plaintiffs DATED this 2nd day of May, 2005, at Seattle, Washington. PROFESSIONAL CORPORATION 601 Union Street, Suite 3100 Seattle WA 98101.1374 TEL 206.623.9900 FAX 206.624.6885

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