Wright et al v. Valor Healthcare, Inc.

Filing 50

STIPULATION AND ORDER re parties' 49 Stipulated Motion; Discovery deadline extended to 7/28/2017, signed by Judge Robert S. Lasnik. (SWT)

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District Court Judge Robert S. Lasnik

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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DEBORAH H. WRIGHT, Personal
Representative of the Estate of LARRY D.
WRIGHT,

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Plaintiff,

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v.

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VALOR HEALTHCARE, INC., et al.,

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Case No. 16-00417 RSL
STIPULATED MOTION FOR
ORDER EXTENDING
DISCOVERY DEADLINE
Noted on motion calendar:
June 15, 2017.

Defendants.

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JOINT STIPULATION

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The parties, by and through their counsel of record, hereby STIPULATE AND
AGREE, to an extension of the July 3, 2017 discovery deadline until July 28, 2017, for the
limited purpose of deposing Dr. Elias Benitez, MD, the United States’ Fed. R. Civ. P.

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30(b)(6) witness1 and various expert witnesses identified by the parties. Good cause exists

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because the purpose for the extension is to complete the remaining depositions in the case and

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to accommodate the varying schedules of counsel and witnesses. The brief extension will not

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affect the current trial date of October 2, 2017, or require any adjustment to the remaining
case scheduling deadlines.

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The deposition of the United States’ witness pertains to Notices of Deposition dated May 25, 2017 and June 15,
2017 directed to the United States pursuant to Fed. R. Civ. P. 30(b)(6).

STIPULATED MOTION FOR ORDER EXTENDING DISCOVERY
DEADLINE (Case No. 16-00417 RSL) - 1 of 2

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Dated this 15th day of June, 2017.

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ANNETTE L. HAYES
United States Attorney

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/s/ Priscilla T. Chan
PRISCILLA T. CHAN, WSBA No. 28533
SARAH K. MOREHEAD, WSBA No. 29680
Assistant United States Attorneys
Western District of Washington
United States Attorney’s Office
700 Stewart Street, Suite 5220
Seattle, Washington 98101-1271
Phone: [phone]
Email: [e-mail]
Email: [e-mail]

/s/ Vernon W. Harkins
VERNON W. HARKINS, WSBA No. 6689
JOHN R. WILSON, WSBA No. 24501
Rush, Hannula, Harkins & Kyler, LLP
Attorneys at Law
4701 South 19th Street, Suite 300
Tacoma, Washington 98405
Phone: [phone]
Email: [e-mail]
Email: [e-mail]

Attorneys for the United States of America

Attorneys for Plaintiff

/s/ Edward J. Hynes
PHILIP J. VANDERHOEF, WSBA No. 14564
EDWARD J. HYNES, WSBA No. 47777
Fain Anderson Vanderhoef Rosendahl
O’Halloran Spillane PLLC
701 – 5th Avenue, Suite 4750
Seattle, Washington 98104
Phone: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Defendant Valor Healthcare, Inc.
ORDER
The parties having so stipulated and agreed, it is hereby SO ORDERED. The Clerk is
directed to send copies of this Order to all counsel of record.
DATED this 20th day of June, 2017.

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A
Robert S. Lasnik

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United States District Judge
STIPULATED MOTION FOR ORDER EXTENDING DISCOVERY
DEADLINE (Case No. 16-00417 RSL) - 2 of 2