United States of America v. Appleby et al

Filing 13

ORDER granting 12 Stipulated Motion to modify the initial deadlines; FRCP 26f Conference Deadline is 7/17/2017, Initial Disclosure Deadline is 7/24/2017, Joint Status Report due by 7/31/2017, signed by Judge Ricardo S Martinez.(RS)

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THE HONORABLE RICARDO S. MARTINEZ

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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UNITED STATES OF AMERICA,
Plaintiff,

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STIPULATED MOTION AND ORDER
MODIFYING
THE INITIAL DEADLINES

v.

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Civil Action No. 2:17-cv-00334

DEBBIE A. APPLEBY, et. al.,
Defendants.

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Pursuant to Fed. R. Civ. P. 6(b)(1) and Local Civil Rule 7(d)(1), the parties, by and through

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their undersigned counsel, respectfully move the Court to modify the deadlines for the parties’

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Fed. R. Civ. P. 26 (f) conference, initial disclosures, and joint status report (collectively, the “initial

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deadlines”) for the following reasons:

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On March 3, 2017, Plaintiff filed its Complaint. See Dkt. No. 1. On April 14, 2017,

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Defendants answered Plaintiff’s Complaint. See Dkt. No. 9. Since the filing of defendants’ answer,

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the parties have attempted advance this case expeditiously and amicably. In particular, the parties

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have engaged in productive discussions and preliminary discovery to explore the possibility of

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early settlement.
STIPULATED MOTION AND ORDER
MODIFYING THE INITIAL
DEADLINES
Civil Action No. 2:17-cv-00334 - 1

UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
[phone]

UNITED STATES DEPARTMENT OF JUSTICE
CIVIL RIGHTS DIVISION
HOUSING AND CIVIL ENFORCEMENT SECTION
950 PENNSYLVANIA AVE NW – NWB
WASHINGTON, DC 20530
[phone]

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On May 11, 2017, at the request of the parties, this Court entered an order extending the
initial deadlines to the following:

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- Deadline for Fed. R. Civ. P. 26(f) Conference:
- Deadline for Initial Disclosures:
- Deadline for Joint Status Report:

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7/17/2017
7/24/2017
7/31/2017

See Dkt. 11 (“Order of May 11, 2017”).

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So that the parties may further explore settlement discussions and conduct other necessary

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preparation for the lawsuit without the unnecessary expenditure of the parties’ or the Court’s

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resources, the parties do hereby AGREE, STIPULATE, and respectfully JOINTLY REQUEST

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that the Court extend the initial deadlines by approximately 45 days and enter the following order:

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1. The schedule set for in the Court’s Order of May 11, 2017 shall be vacated.

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2. The following schedule shall apply:

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-

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Deadline for Fed. R. Civ. P. 26(f) Conference:
Deadline for Initial Disclosures:
Deadline for Joint Status Report.
`

8/31/2017
9/10/2017
9/17/2017

So stipulated and respectfully submitted this 14th day of July, 2017.

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STIPULATED MOTION AND ORDER
MODIFYING THE INITIAL
DEADLINES
Civil Action No. 2:17-cv-00334 - 2

UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
[phone]

UNITED STATES DEPARTMENT OF JUSTICE
CIVIL RIGHTS DIVISION
HOUSING AND CIVIL ENFORCEMENT SECTION
950 PENNSYLVANIA AVE NW – NWB
WASHINGTON, DC 20530
[phone]

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Respectfully submitted,

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DATED: July 14, 2017

DATED: July 14, 2017

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JEFFERSON B. SESSIONS III
Attorney General

LOEFFLER LAW GROUP, PLLC

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T.E. WHEELER, II
Acting Assistant Attorney General
Civil Rights Division
SAMEENA SHINA MAJEED
Chief
Housing and Civil Enforcement Section

/s/ Jeana Poloni
JEANA POLONI, WSBA #43172
500 Union Street, Suite 1025
Seattle, Washington 98101
Phone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendants

TIMOTHY J. MORAN
Deputy Chief
KATHRYN LEGOMSKY
Trial Attorney
Housing and Civil Enforcement Section
Civil Rights Division
U.S. Department of Justice
950 Pennsylvania Avenue, NW – NWB
Washington, DC 20530
Tel: [phone]
Fax: [phone]
[e-mail]

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ANNETTE L. HAYES
United States Attorney
/s/ J. Michael Diaz
J. MICHAEL DIAZ, WSBA # 38100
Assistant United States Attorney
700 Stewart Street, Suite 5220
Seattle, Washington 98101
Phone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Plaintiff
United States for America

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STIPULATED MOTION AND ORDER
MODIFYING THE INITIAL
DEADLINES
Civil Action No. 2:17-cv-00334 - 3

UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
[phone]

UNITED STATES DEPARTMENT OF JUSTICE
CIVIL RIGHTS DIVISION
HOUSING AND CIVIL ENFORCEMENT SECTION
950 PENNSYLVANIA AVE NW – NWB
WASHINGTON, DC 20530
[phone]

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ORDER

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The parties having so stipulated, it is so ORDERED.

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DATED this 17 day of July 2017.

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A

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RICARDO S. MARTINEZ
CHIEF UNITED STATES DISTRICT JUDGE

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STIPULATED MOTION AND ORDER
MODIFYING THE INITIAL
DEADLINES
Civil Action No. 2:17-cv-00334 - 4

UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
[phone]

UNITED STATES DEPARTMENT OF JUSTICE
CIVIL RIGHTS DIVISION
HOUSING AND CIVIL ENFORCEMENT SECTION
950 PENNSYLVANIA AVE NW – NWB
WASHINGTON, DC 20530
[phone]