Mason v. Washington State et al

Filing 54

STIPULATION AND ORDER extending the deadline for exchanging Initial Disclosures and filing a combined Joint Status Report to 12/22/2017, signed by Judge Marsha J. Pechman. (PM)

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THE HONORABLE MARSHA J. PECHMAN

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IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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ELTON MASON, an individual, dba
WASHINGTON STATE TRUCKING, a sole
proprietorship,
Plaintiffs,

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vs.
WASHINGTON STATE, a state governmental
entity, WASHINGTON STATE
DEPARTMENT OF TRANSPORTATION, a
political subdivision governmental entity,
OFFICE OF MINORITY WOMEN
BUSINESS ENTERPRISES, a subdivision
governmental entity, SEATTLE TUNNEL
PARTNERS, a Joint Venture Dragados, USA,
and Tutor Perini Corporation,

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Defendants.

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STIPULATION AND ORDER EXTENDING
DEADLINE FOR EXCHANGE OF INITIAL
DISCLOSURES AND FILING OF JOINT STATUS
REPORT – CASE NO. 17-186-MJP - 1

Case No. 2:17-cv-00186-MJP

JOINT STIPULATION AND ORDER
EXTENDING DEADLINE FOR
EXCHANGE OF INITIAL
DISCLOSURES AND FILING OF
JOINT STATUS REPORT

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STIPULATION

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IT IS HEREBY STIPULATED by and between all counsel that, subject to Court approval,

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the deadline for the parties to file a combined joint status report and exchange initial disclosures shall

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be extended from November 17, 2017, to December 22, 2017.

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All Defendants in this action have moved to dismiss the Plaintiff’s First Amended Complaint

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in full. The parties have completed briefing the matter, and the motions to dismiss are currently

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pending before the Court. The Court’s ruling on these motions could affect the scope of the litigation,

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including whether the case proceeds at all; if it does, what information would be relevant in

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exchanging initial disclosures; and what the parties would need to focus on in drafting the combined

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joint status report. Subject to Court approval, therefore, the parties have stipulated to an extension of

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that deadline by slightly more than 30 days (to accommodate counsel’s upcoming trial schedule).

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There is good cause for the stipulation, as the Court’s ruling on the currently pending motions may

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resolve the litigation entirely or narrow the scope of relevant information. If the Court approves the

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parties’ stipulation, the deadline for the parties to exchange initial disclosures and file a combined

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joint status report shall be extended to December 22, 2017.

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For the above reasons, and subject to Court approval, the parties hereby agree and stipulate

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that the deadline for the filing of a combined joint status report and exchange of initial disclosures

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shall be extended to December 22, 2017.

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IT IS SO STIPULATED.

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DATED this 8th day of November, 2017.

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STIPULATION AND ORDER EXTENDING
DEADLINE FOR EXCHANGE OF INITIAL
DISCLOSURES AND FILING OF JOINT STATUS
REPORT – CASE NO. 17-186-MJP - 2

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CALFO EAKES & OSTROVSKY PLLC

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By
s/ Patricia A. Eakes
Patricia A. Eakes, WSBA# 18888
Nathan Bays, WSBA #43025
Lindsey Mundt, WSBA #49394
1301 Second Avenue, Suite 2800
Seattle, WA 98101
Phone: [phone]
Fax: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants, Seattle Tunnel Partners, a Joint
Venture, Dragados USA, Inc., Tutor Perini Corporation,
Chris Dixon, and Russell Streadbeck

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ROBERT W. FERGUSON,
Attorney General
By _____s/ Celeste Stokes______________
Robert W. Ferguson, Attorney General
Celeste Stokes, WSBA #12180, OID # 91019
Assistant Attorney General
800 Fifth Avenue, Suite 2000
Seattle, WA 98104
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Defendants The State of Washington,
Washington State Department of Transportation, Office of
Minority & Women’s Business Enterprises, and Lynne
Peterson

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BEVERLY GRANT LAW FIRM, P.S.

By ______s/ Beverly Grant_____________
Beverly Grant, WSBA # 8034
Elizabeth Lunde, WSBA # 51565
Beverly Grant Law Firm, P.S.
3929 Bridgeport Way W. Ste. 208
University Place, WA 98464
Phone: [phone]
Email: [e-mail]
Attorneys for Plaintiff Elton Mason

STIPULATION AND ORDER EXTENDING
DEADLINE FOR EXCHANGE OF INITIAL
DISCLOSURES AND FILING OF JOINT STATUS
REPORT – CASE NO. 17-186-MJP - 3

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ORDER
THIS MATTER having come before Court upon stipulation of counsel, and the Court having
examined the records and being fully advised in the matter, now, therefore,
IT IS HEREBY ORDERED that the deadline for the parties to exchange initial disclosures
and file a combined joint status report shall be extended to December 22, 2017.
DATED this _9th_ day of November, 2017.

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A

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Marsha J. Pechman
United States District Judge

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STIPULATION AND ORDER EXTENDING
DEADLINE FOR EXCHANGE OF INITIAL
DISCLOSURES AND FILING OF JOINT STATUS
REPORT – CASE NO. 17-186-MJP - 4

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CERTIFICATE OF SERVICE

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The undersigned hereby certifies that on November 8, 2017, I electronically filed the

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foregoing with the Clerk of the Court using the CM/ECF system, which will send notification of

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such filing to all CM/ECF participants.

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DATED this 8th day of November, 2017.

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s/Erica Knerr
Erica Knerr

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STIPULATION AND ORDER EXTENDING
DEADLINE FOR EXCHANGE OF INITIAL
DISCLOSURES AND FILING OF JOINT STATUS
REPORT – CASE NO. 17-186-MJP - 5