Chen et al v. The City of Redmond, et al

Filing 183

STIPULATION AND ORDER to extend discovery completion date re parties' 182 Stipulated Motion. Signed by Judge James L. Robart. (SWT)

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Honorable James L. Robart

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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SUSAN CHEN, et al.,
Plaintiffs,

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v.

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NATALIE D’AMICO, et al.,

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STIPULATED MOTION AND
ORDER TO EXTEND DISCOVERY
COMPLETION DATE
NOTE FOR HEARING: 09/16/2019

Defendants.

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NO. C16-1877 JLR

BY STIPULATION AND AGREEMENT, the Plaintiffs and the Defendants, by and
through their respective counsel of record, request the Court grant the following relief:
1.

Extend the discovery completion date from September 16, 2019, the date

established by the Court’s Minute Order Setting Trial Dates and Related Dates (Minute Order
10/03/2018, Dkt. #102, to October 11, 2019, solely as to the depositions identified below.
2.

The requested extension will allow the parties to complete depositions that were

properly noted prior to the discovery completion date but which have not yet been able to be
completed as a result of scheduling issues, including and limited to: the deposition of plaintiff Susan
Chen, which had to be continued due to an emergency requiring her return to China; and the
completion of the Rule 30(b)(6) deposition of Defendant DSHS for which the scheduling of
witnesses on four topics is in progress.

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STIPULATED MOT. & [PROPOSED]
ORDER TO EXTEND DISCOVERY
COMPLETION DATE
(C16-1877 JLR)

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ATTORNEY GENERAL OF WASHINGTON
Torts Division
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]

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3.

The parties do not believe the requested extension will interfere with any of the other

dates established by the Court’s Minute Order of October 3, 2018.
SIGNED AND STIPULATED TO THIS 16th day of September, 2019.
ROBERT W. FERGUSON
Attorney General

DORSEY & WHITNEY LLP

s/ Scott M. Barbara
SCOTT M. BARBARA, WSBA #20885
Assistant Attorney General
Attorneys for State Defendants
800 Fifth Ave, Ste 2000
Seattle, WA 98104
Tel: [phone]
Email: [e-mail]

s/ Shawn Larsen-Bright
SHAWN LARSEN-BRIGHT, WSBA #37066
Attorneys for Plaintiffs Chen and J.L.
701 Fifth Ave, Ste 6100
Seattle, WA 98104
Tel: [phone]
Email: [e-mail]

OGDEN MURPHY WALLACE, PLLC

MYERS & COMPANY, P.L.L.C.

s/ Aaron P. Riensche
AARON P. RIENSCHE, WSBA #37202
Attorneys for Redmond Defendants
901 Fifth Ave, Ste 3500
Seattle, WA 98164
Tel: [phone]
Email: [e-mail]

s/ Michael D. Myers
MICHAEL DAVID MYERS, WSBA #22468
Attorneys for Plaintiffs Lian and L.L.
1530 Eastlake Ave E
Seattle, WA 98102
Tel: [phone]
Email: [e-mail]

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ORDER
IT IS SO ORDERED.
DATED THIS 17th day of September, 2019.

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A

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JAMES L. ROBART
United States District Judge

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STIPULATED MOT. & [PROPOSED]
ORDER TO EXTEND DISCOVERY
COMPLETION DATE
(C16-1877 JLR)

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ATTORNEY GENERAL OF WASHINGTON
Torts Division
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]