Rosenberg v. CCS Commercial, LLC et al

Filing 53

ORDER granting 52 Stipulated Motion Amending Case Schedule. The deadline for the Expert Witness Disclosure/Reports under FRCP 26(a)(2) is continued to 4/13/2018. Signed by Judge Marsha J. Pechman. (PM)

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Honorable Marsha J. Pechman
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IN THE UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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AYANNA ROSENBERG, individually, and on
behalf of all those similarly situated,

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Plaintiff,

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Case No. 2:17-cv-00476-MJP
STIPULATED MOTION AND ORDER
AMENDING CASE SCHEDULE

v.

NOTE ON MOTION CALENDAR:
MARCH 7, 2018

CCS COMMERCIAL, L.L.C., (d/b/a Credit
Collection Services Commercial), and
PROGRESSIVE DIRECT INSURANCE
COMPANY,

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Defendants.
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Pursuant to LCR 7(d)(1), LCR 10(g), and the Court’s Chamber Procedures, Plaintiff Ayanna

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Rosenberg (“Plaintiff”) and Defendants CCS Commercial, LLC and Progressive Direct Insurance

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Company (collectively, “Defendants”), by and through their counsel, hereby stipulate and move for a

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one-month continuance of the deadline for the parties to exchange expert witness reports pursuant to

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FRCP 26(a)(2)(B) due to the current schedule for class certification.

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STIPULATED MOTION

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The parties agree and stipulate as follows:

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The noting date for plaintiff’s motion for class certification is March 9, 2018.

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STIPULATED MOTION AND ORDER AMENDING CASE
SCHEDULE - PAGE 1

The deadline for the parties to exchange expert witness reports is March 14, 2018. (Dkt. #

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22.)

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The parties expect that the Court will not resolve plaintiff’s motion for class certification by

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the current expert witness deadline. Thus, the current schedule may require the parties to exchange

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expert reports regarding liability before the parties know the existence or scope of the potential class

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in this case. The parties believe that a one month continuance to exchange expert reports will

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provide sufficient time for the Court to resolve plaintiff’s motion for class certification without

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disrupting the remaining case schedule.

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Accordingly, the parties agree and stipulate that good cause exists to continue the deadline to
exchange expert witness reports by approximately one month, to April 13, 2018.
STIPULATED and AGREED:

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Dated this 7th day of March, 2018

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TOUSLEY BRAIN STEPHENS PLLC

COZEN O’CONNOR

By: s/ Chase Alvord
Chase Alvord, WSBA No. 26080
Email: [e-mail]
James M. Bulthuis, WSBA No. 44089
Email: [e-mail]

By:

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s/ Anusha E. Jones
William H. Walsh, WSBA No. 21911
Email: [e-mail]
Anusha E. Jones, WSBA No. 52989
E-mail: [e-mail]

IDE LAW OFFICE
Matthew James Ide, WSBA No. 26002
Email: [e-mail]

Attorneys for Defendant
CCS Commercial, LLC

Attorney for Plaintiff Ayanna Rosenberg,
individually, and on Behalf of all those
similarly situated

HOLLAND & KNIGHT
By: s/ Shannon Armstrong
J. Matthew Donohue, WSBA No. 52455
Email: [e-mail]
Shannon Armstrong, WSBA No. 45947
Email: [e-mail]
Attorneys for Defendant Progressive Direct
Insurance Company

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STIPULATED MOTION AND ORDER AMENDING CASE
SCHEDULE - PAGE 2

ORDER

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Pursuant to the above stipulated motion, and good cause appearing, it is so ordered that the

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deadline to exchange expert witness reports is extended to April 13, 2018, and that the Case Schedule

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be amended as indicated.

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DATED this _8th_ day of _March_, 2018.

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A

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Marsha J. Pechman
United States District Judge

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STIPULATED MOTION AND ORDER AMENDING CASE
SCHEDULE - PAGE 3

CERTIFICATE OF SERVICE

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I hereby certify that I caused the foregoing STIPULATED MOTION AND [PROPOSED]
ORDER AMENDING CASE SCHEDULE to be served on the following person[s]:

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Chase Christian Alvord
James M. Bulthuis
Tousely Brain Stephens
1700 Seventh Avenue, Suite 2200
Settle, WA 98101
[e-mail]
[e-mail]

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Matthew James Ide
Ide Law Office
7900 SE 28th St., Suite 500
Mercer Island, WA 98040
[e-mail]

Kevin A. Michael
William Harrison Walsh
Anusha Jones
Cozen O’Connor
999 Third Avenue, Suite 1900
Seattle, WA 98104
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendant CCS Commercial LLC

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Attorneys for Plaintiff
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by causing the document to be delivered by the following indicated method or methods:

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

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by mailing full, true and correct copies thereof in sealed, first class postage prepaid envelopes,
addressed to the parties and/or their attorneys as shown above, to the last-known office addresses of
the parties and/or attorneys, and deposited with the United States Postal Service at Portland, Oregon,
on the date set forth below.

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by CM/ECF electronically mailed notice from the Court on the date set forth below.

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by causing full, true, and correct copies thereof to be hand-delivered to the parties and/or their
attorneys at their last-known office addresses listed above on the date set forth below.
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by sending full, true, and correct copies thereof, via overnight courier in sealed, prepaid
envelopes, addressed to the parties and/or their attorneys as shown above, to the last-known office
addresses of the parties and/or their attorneys, on the date set forth below.
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by faxing full, true, and correct copies thereof to the fax machines which are the last-known fax
numbers for the parties’ and/or attorneys’ offices, on the date set forth below.
DATED March 7, 2018.

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s/ Kristin M. Asai
Kristin M. Asai

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HOLLAND & KNIGHT LLP

CERTIFICATE OF SERVICE – PAGE 1
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2300 US Bancorp Tower
111 SW Fifth Avenue
Portland, OR 97204
Telephone: [phone]