Townsley v. Geico Indemnity Company

Filing 11

STIPULATION AND ORDER REGARDING EXPERT DISCLOSURES by Judge Robert S. Lasnik; Expert Witness Disclosure/Reports under FRCP 26(a)(2) due by 6/7/2013, Rebuttal Expert Disclosure/Reports due by 6/21/2013. (TF)

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HONORABLE ROBERT S.LASNIK

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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NO. 12-cv-01909-RSL

ESTRALITTA TOWNSLEY,
Plaintiff,
v.
GEICO INDEMNITY COMPANY, an
insurance company,

STIPULATION AND
ORDER REGARDING EXPERT
DISCLOSURES

Defendant.

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I.

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STIPULATION

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Come now the parties, by and through their undersigned counsel of record, and hereby

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stipulate to and respectfully request that the Court enter an order extending the May 8, 2013

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FRCP 26(a)(2) expert disclosure and report deadline to June 7, 2013. The parties also request

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that the deadline for disclosure of rebuttal experts be set for June 21, 2013.

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This claim arises out of an underinsured motorist and extra-contractual dispute with
Geico for alleged failure to negotiate in good faith with the plaintiff who was injured by an

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STIPULATION FOR AND PROPOSED
ORDER RE: EXPERT DISCLOSURES
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SCOTT M. DONALDSON, P.S.
ATTORNEY
15500 BOTHELL WAY NE
Lake Forest Park WA 98155-6748
FAX [phone]
PHONE [phone]

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underinsured driver in an automobile collision on May 4, 2010 within King County,

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Washington. Plaintiff Townsley initially brought suit in King County Superior Court against

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Geico, her UIM insurer.

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Geico has declined to resolve this matter via arbitration. Geico’s insurance contract is a
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contract of adhesion as it relates to resolving UIM disputes or disagreements and provides that
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“binding, voluntary arbitration … shall be composed of a single arbitrator selected by mutual
agreement … [unless] agreement [could not] be reached on selection of an arbitrator.”
Geico removed this case from King County Superior Court to United States District
Court, Western District of Washington, at Seattle.

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The parties believe that extending the expert report deadline to June 7, 2013 and the

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rebuttal expert deadline to June 21, 2013 will allow adequate time to schedule any depositions

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and complete expert reports.
DATED this 17th day of April, 2013.

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SCOTT M. DONALDSON, P.S.

WILSON SMITH COCHRAN DICKERSON

s/ Scott M. Donaldson
Scott M. Donaldson, WSBA #12623
15500 Bothell Way N.E.
Lake Forest Park, WA 98155-6748
Telephone: [phone]
Facsimile: 425-806-2020
E-mail: [e-mail]

s/ Dylan E. Jackson #29220
Alfred E. Donohue, WSBA #32774
901 Fifth Avenue, Suite 1700
Seattle, WA 98164
Telephone: [phone]
Facsimile: 206-623-9273
E-mail: [e-mail]

Attorney for Plaintiff

Attorney for Defendant

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STIPULATION FOR AND PROPOSED
ORDER RE: EXPERT DISCLOSURES
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SCOTT M. DONALDSON, P.S.
ATTORNEY
15500 BOTHELL WAY NE
Lake Forest Park WA 98155-6748
FAX [phone]
PHONE [phone]

II.

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ORDER

THIS MATTER coming on to be heard before the undersigned judge of the above-entitled
Court based upon the foregoing stipulation of the parties, and the Court being fully advised in the

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premises,
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IT IS SO ORDERED that the parties shall comply with the following deadlines for the

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FRCP 26(a)(2) expert disclosures:
All parties to provide Expert Witness Disclosures/Reports by June 7, 2013. The deadline
for disclosure of rebuttal experts is June 21, 2013.
DATED this 23rd day of April, 2013.

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A
Robert S. Lasnik

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United States District Judge 

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Presented by:

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SCOTT M. DONALDSON, P.S.

WILSON SMITH COCHRAN DICKERSON

s/ Scott M. Donaldson
Scott M. Donaldson, WSBA #12623
15500 Bothell Way N.E.
Lake Forest Park, WA 98155-6748
Telephone: [phone]
Facsimile: 425-806-2020
E-mail: [e-mail]

s/ Dylan E. Jackson #29220
Alfred E. Donohue, WSBA #32774
901 Fifth Avenue, Suite 1700
Seattle, WA 98164
Telephone: [phone]
Facsimile: 206-623-9273
E-mail: [e-mail]

Attorney for Plaintiff

Attorney for Defendant

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STIPULATION FOR AND PROPOSED
ORDER RE: EXPERT DISCLOSURES
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SCOTT M. DONALDSON, P.S.
ATTORNEY
15500 BOTHELL WAY NE
Lake Forest Park WA 98155-6748
FAX [phone]
PHONE [phone]