Cristalla Condominium Association v. Affiliated FM Insurance Company

Filing 31

STIPULATED MOTION AND ORDER 29 to Amend Order Setting Trial Date & Related Dates, by Judge Robert S. Lasnik. (KERR)

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The Honorable Robert S. Lasnik

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON AT SEATTLE

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10 CRISTALLA CONDOMINIUM
ASSOCIATION, a Washington nonprofit
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corporation,
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Plaintiff,
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No. 2:16-cv-1838
STIPULATED MOTION & ORDER TO
AMEND ORDER SETTING TRIAL DATE
& RELATED DATES

vs.

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15 AFFILIATED FM INSURANCE COMPANY,
16 a foreign insurance company,
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Defendant.
COME NOW the parties, Plaintiff Cristalla Condominium Association (“Cristalla”),
and Defendant Affiliated FM Insurance Company (“AFM”), by and through their counsel of
record herein, and hereby stipulate and agree to this Court’s entry of the subjoined, agreed

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Order below for the reasons set forth herein.
STIPULATION

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1.

Plaintiff Cristalla and Defendant AFM stipulate to this Court’s entry of the

25 agreed Order below extending the current trial date and all other pre-trial cut-off dates by 60
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STIPULATED MOTION AND ORDER AMENDING MINUTE
ORDER SETTING TRIAL DATE & RELATED DATES
(Cause No. 2:16-cv-1838) – 1
SMS6500.018/2692767x

901 FIFTH AVENUE, SUITE 1700
SEATTLE, WASHINGTON 98164
TELEPHONE: [phone]
FAX: [phone]

1 days—including cut-off dates for the completion of discovery, the settlement conference date,
2 and the dates for filing all dispositive motions and motions in limine.
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2.

The parties stipulate to this extension for several reasons. First, the parties

wish to proceed to mediation and are presently in the process of scheduling a mediation to
occur during the month of December 2017 with mediator Tom Harris. Second, Plaintiff

7 wishes to forestall certain deposition discovery requested by Defendant, permitting only the
8 Rule 30(b)(6) deposition of Plaintiff prior to mediation and conducting all other depositions
9 after mediation (if mediation proves unsuccessful). Third, the parties are awaiting this Court’s
10 Order on Plaintiff’s pending Motion for Partial Summary Judgment (Docket #17), which has
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been fully briefed, the outcome of which may impact the scope of discovery and issues for
trial. Fourth, Defendant AFM’s lead trial counsel, Scott Stickney, has a family obligation that
makes the presently set trial date of March 5, 2018, unworkable.
3.

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The parties believe a 60-day continuance will be sufficient to accommodate

16 their needs and to allow for a mediation to occur in December 2018, after which discovery
17 may be completed if mediation is unsuccessful, affording the parties sufficient time to be
18 ready for trial on or about May 7, 2018.
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4.

While the parties have filed previous stipulated motions to make minor

alterations to other pre-trial deadlines (which motions this Court has granted), this is the first
request for a change in the trial date. Neither party foresees the need for any further trial

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STIPULATED MOTION AND ORDER AMENDING MINUTE
ORDER SETTING TRIAL DATE & RELATED DATES
(Cause No. 2:16-cv-1838) – 2
SMS6500.018/2692767x

901 FIFTH AVENUE, SUITE 1700
SEATTLE, WASHINGTON 98164
TELEPHONE: [phone]
FAX: [phone]

1 continuances other than the one herein requested.
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DATED:

October 11, 2017

s/ Scott M. Stickney
Scott M. Stickney, WSBA No. 14540
[e-mail]
Maria E. Sotirhos, WSBA No. 21726
[e-mail]
WILSON SMITH COCHRAN DICKERSON
901 Fifth Avenue, Suite 1700
Seattle, WA 98164
[phone] phone
[phone] fax
Attorneys for Defendant
Affiliated FM Insurance Company

s/ Todd C. Hayes
Todd C. Hayes, WSBA No. 26361
[e-mail]
HARPER │HAYES PLLC
One Union Square
600 University St., Ste. 2420
Seattle, WA 98101
[phone] phone
[phone]
Attorneys for Plaintiff
Cristalla Condominium Association

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ORDER

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THIS MATTER having come on regularly for hearing upon the Stipulation of Plaintiff

15 Cristalla and Defendant AFM, above, and the Court being fully advised, now, therefore, it is
16 hereby ORDERED, ADJUDGED and DECREED as follows:
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1.

The Court’s Minute Order Setting Trial & Related Dates (Docket # 14) is hereby

vacated and the present trial date of March 5, 2018, is stricken.
2.

The Clerk shall enter a new Minute Order Setting Trial & Related Dates with a

new trial date on or about May 7, 2018.
DATED: October 17, 2017.

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A
Robert S. Lasnik

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United States District Judge 

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STIPULATED MOTION AND ORDER AMENDING MINUTE
ORDER SETTING TRIAL DATE & RELATED DATES
(Cause No. 2:16-cv-1838) – 3
SMS6500.018/2692767x

901 FIFTH AVENUE, SUITE 1700
SEATTLE, WASHINGTON 98164
TELEPHONE: [phone]
FAX: [phone]

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Presented by:
By: s/ Scott M. Stickney
Scott M. Stickney, WSBA No. 14540
[e-mail]
Maria E. Sotirhos, WSBA No. 21726
[e-mail]
WILSON SMITH COCHRAN DICKERSON
901 Fifth Avenue, Suite 1700
Seattle, WA 98164
[phone] phone
[phone] fax
Attorneys for Defendant
Affiliated FM Insurance Company

11 By: s/ Todd C. Hayes
Todd C. Hayes, WSBA No. 26361
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[e-mail]
HARPER │HAYES PLLC
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One Union Square
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600 University St., Ste. 2420
Seattle, WA 98101
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[phone] phone
[phone]
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Attorneys for Plaintiff
17 Cristalla Condominium Association
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STIPULATED MOTION AND ORDER AMENDING MINUTE
ORDER SETTING TRIAL DATE & RELATED DATES
(Cause No. 2:16-cv-1838) – 4
SMS6500.018/2692767x

901 FIFTH AVENUE, SUITE 1700
SEATTLE, WASHINGTON 98164
TELEPHONE: [phone]
FAX: [phone]