Dougherty v. Barrett Business Services Inc

Filing 51

STIPULATION AND ORDER SETTING BRIEFING SCHEDULE ON CROSS-MOTIONS REGARDING DISCOVERY by Judge Thomas S. Zilly. Defendant shall provide Plaintiff a copy of any declarations to be used in defendant's motion for protective order on or before March 17, 2017; Both plaintiff's motion to compel and defendant's motion for protective order shall be filed and served on or before March 30, 2017, and noted for April 21, 2017; Both responses to the cross-motions shall be filed and served on or before April 21, 2017. No reply shall be filed unless requested by the Court. (PM)

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The Honorable Thomas S. Zilly

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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AMANDA DOUGHERTY, individually
and as a representative of the class,
Case No. 2:15-cv-01501-TSZ
Plaintiff,

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STIPULATION AND ORDER SETTING
BRIEFING SCHEDULE ON CROSSMOTIONS REGARDING DISCOVERY

v.
BARRETT BUSINESS SERVICES, INC.,
Defendant.

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The parties have a dispute regarding the scope of discovery. After conferring,

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plaintiff intends to file a motion to compel and defendant intends to file a cross motion for a

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protective order. Pursuant to LCR 7(k), the parties hereby stipulate by and between the

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undersigned, subject to the approval of the Court, that the following schedule shall govern their

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cross motions:

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1.

Defendant shall provide plaintiff a copy of any declarations to be used in

defendant's motion for protective order on or before March 17, 2017;
2.

Both plaintiff's motion to compel and defendant's motion for protective

order shall be filed and served on or before March 30, 2017;

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3.

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Both responses to the cross motions shall be filed and served on or before

April 21, 2017.

STIPULATION AND ORDER SETTING BRIEFING
SCHEDULE ON CROSS-MOTIONS REGARDING
DISCOVERY- 1
(Case No. 2:15-cv-01501-TSZ)

MILLER NASH GRAHAM & DUNN LLP
AT T ORNE YS AT LA W
T : 206. 624. 8300 | F: 206. 340. 9599
PIE R 70
2801 ALASK AN WAY, S UIT E 300
SE AT T LE , WASHI NGT ON 98121

4835-8015-3668.1

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Both parties are requesting and stipulating to extra time between the filing of the

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motions and the filing of the responses due to the fact that attorneys for both parties have

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preplanned trips and will be out of the office at different times during the first two weeks in

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April. To accommodate the schedule of both parties the parties are stipulating to and requesting

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the additional time for the responses.

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DATED this 7th day of March, 2017.

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By: /s/ Joseph Vance, P.C.
Joseph Vance, P.C., WSB No. 25531
Megan L. Starich, WSB No. 47520
Miller Nash Graham & Dunn LLP
2801 Alaskan Way, Suite 300
Seattle, Washington 98121
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
[e-mail]
Attorneys for Defendant

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By: /s/ E. Michelle Drake
Beth E. Terrell, WSB No. 26759
Terrell Marshall Law Group PLLC
936 North 34th Street, Suite 300
Seattle, Washington 98103-8869
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]

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E. Michelle Drake, Admitted Pro Hac Vice
John G. Albanese, Admitted Pro Hac Vice
Berger & Montague, P.C.
43 S.E. Main Street, Suite 505
Minneapolis, Minnesota 55414
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
[e-mail]

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Attorneys for Plaintiff

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STIPULATION AND ORDER SETTING BRIEFING
SCHEDULE ON CROSS-MOTIONS REGARDING
DISCOVERY- 2
(Case No. 2:15-cv-01501-TSZ)

MILLER NASH GRAHAM & DUNN LLP
AT T ORNE YS AT LA W
T : 206. 624. 8300 | F: 206. 340. 9599
PIE R 70
2801 ALASK AN WAY, S UIT E 300
SE AT T LE , WASHI NGT ON 98121

4835-8015-3668.1

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PURSUANT TO STIPULATION, IT IS ORDERED:

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The following briefing schedule shall apply to the parties’ cross-motions to compel and

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for protective order;

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1.

Defendant shall provide Plaintiff a copy of any declarations to be used in

defendant's motion for protective order on or before March 17, 2017;
2.

Both plaintiff's motion to compel and defendant's motion for protective order shall

be filed and served on or before March 30, 2017, and noted for April 21, 2017; and
3.

Both responses to the cross-motions shall be filed and served on or before

April 21, 2017. No reply shall be filed unless requested by the Court.

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DATED this 7th day of March, 2017.

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A

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Thomas S. Zilly
United States District Judge

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Presented by:

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MILLER NASH GRAHAM & DUNN, LLP

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/s/ Joseph Vance, P.C.
Joseph Vance, P.C., WSB No. 25531
Megan L. Starich, WSB No. 47520
Miller Nash Graham & Dunn LLP
2801 Alaskan Way, Suite 300
Seattle, Washington 98121
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
[e-mail]
Attorneys for Defendant

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STIPULATION AND ORDER SETTING BRIEFING
SCHEDULE ON CROSS-MOTIONS REGARDING
DISCOVERY- 3
(Case No. 2:15-cv-01501-TSZ)

MILLER NASH GRAHAM & DUNN LLP
AT T ORNE YS AT LA W
T : 206. 624. 8300 | F: 206. 340. 9599
PIE R 70
2801 ALASK AN WAY, S UIT E 300
SE AT T LE , WASHI NGT ON 98121

4835-8015-3668.1