Zamelis v. Wingfoot Commercial Tire Systems LLC

Filing 11

STIPULATION AND ORDER TO FILE AMENDED ANSWER AND COUNTERCLAIM AND ISSUE NEW SCHEDULING ORDER, by Judge Ricardo S Martinez. (VP)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 RELIEF REQUESTED vs. WINGFOOT COMMERCIAL TIRE SYSTEMS, LLC, a Washington Limited Liability Company, Defendant. JON ZAMELIS, an individual, Plaintiff,

The Honorable Ricardo S. Martinez

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON AT SEATTLE

No. C08-1588 RSM STIPULATED ORDER TO FILE AMENDED ANSWER AND COUNTERCLAIM AND ISSUE NEW SCHEDULING ORDER

The parties, Plaintiff Jon Zamelis and Defendant Wingfoot Commercial Tire Systems, LLC, have hereby stipulated and agreed to allow Defendant to file its Amended Answer and Counterclaim pursuant to Rule 15(a)(2). Consequently, the parties respectfully request that this Court (1) extend the dates contained in the Court's Order Setting Trial and Related Dates, including the reports from expert witnesses which are currently due on May 1, 2009, and (2) issue a new Order Regarding Initial Disclosures, Joint Status Report, And Early Settlement. The parties make this request because Defendant plans to file an Amended Answer and Counterclaim sometime the week of May 4, 2009, after which the parties have agreed that they will request a new Scheduling Order from the Court. Consequently, the parties will not be ready to file their expert witness reports on May 1, 2009.
STIPULATED ORDER TO FILE AMENDED ANSWER AND COUNTERCLAIM AND ISSUE NEW SCHEDULING ORDER- 1 CASE NO. C08-1588 RSM
LITTLER MENDELSON P.C. One Union Square 600 University Street, Suite 3200 Sea t t l e , WA 98101.3122 206.623.3300

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26
STIPULATED ORDER TO FILE AMENDED ANSWER AND COUNTERCLAIM AND ISSUE NEW SCHEDULING ORDER- 2 CASE NO. C08-1588 RSM
LITTLER MENDELSON P.C. One Union Square 600 University Street, Suite 3200 Sea t t l e , WA 98101.3122 206.623.3300

Dated: April 30, 2009

/s/Joanna M. Silverstein Leigh Ann Tift, WSBA #11776 [e-mail] Joanna M. Silverstein, WSBA #38577 [e-mail] LITTLER MENDELSON A Professional Corporation One Union Square 600 University Street, Suite 3200 Seattle, WA 98101.3122 Phone: [phone] Fax: [phone] Attorneys for Defendant WINGFOOT COMMERCIAL TIRE SYSTEMS, LLC

Dated: April 30, 2009

/s/Jeffrey C. Wishko Jeffrey C. Wishko, WSBA #12885 [e-mail] Bell & Ingram, P.S. 2918 Colby Avenue, Suite 201 Everett, Washington 98201 Tel: [phone] Fax: [phone] Attorneys for Plaintiff JON ZAMELIS

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 PRESENTED BY: /s/Joanna M. Silverstein Leigh Ann Tift, WSBA #11776 [e-mail] Joanna M. Silverstein, WSBA #38577 [e-mail] LITTLER MENDELSON A Professional Corporation One Union Square 600 University Street, Suite 3200 Seattle, WA 98101.3122 Phone: [phone] Fax: [phone] Attorneys for Defendant /s/Jeffrey C. Wishko Jeffrey C. Wishko, WSBA #12885 [e-mail] Bell & Ingram, P.S. 2918 Colby Avenue, Suite 201 Everett, Washington 98201 Tel: [phone] Fax: [phone] Attorneys for Plaintiff

ORDER Based on the foregoing Stipulation, it is hereby ORDERED, ADJUDGED AND DECREED as follows: The stipulated Motion to Extend Trial and Related Dates is GRANTED. The clerk will issue a New Order Regarding Initial Disclosures, Joint Status Report, and Early Settlement. DATED: May 4, 2009

A

RICARDO S. MARTINEZ UNITED STATES DISTRICT JUDGE

STIPULATED ORDER TO FILE AMENDED ANSWER AND COUNTERCLAIM AND ISSUE NEW SCHEDULING ORDER- 3 CASE NO. C08-1588 RSM

LITTLER MENDELSON P.C. One Union Square 600 University Street, Suite 3200 Sea t t l e , WA 98101.3122 206.623.3300