Rosenberg v. CCS Commercial, LLC et al

Filing 74

ORDER re: 73 Stipulated Motion to Amend Summary Judgment Schedule. Defendants Progressive and CCS's response to Plaintiff's 65 Motion for Partial Summary Judgment due 6/20/2018; Plaintiff's combined response to Progressive's 71 Motion for summary judgment and reply in support of Plaintiff's 65 motion for partial summary judgment due 7/2/2018. Progressive's reply to it's 71 motion for summary judgment due 7/6/2018. Plaintiff's 65 motion for partial summary judgment and Progressive's 71 motion for summary judgment are both noted for 7/6/2018. 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 SUMMARY JUDGMENT
SCHEDULE

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

NOTE ON MOTION CALENDAR:
JUNE 13, 2018

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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, defendant CCS Commercial, LLC (“CCS”), and defendant Progressive Direct Insurance

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

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consolidated briefing schedule on their cross motions for summary judgment under LCR 7(k).
STIPULATED MOTION

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The parties agree and stipulate as follows:

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Plaintiff filed a motion for partial summary judgment on May 31, 2018, with a noting date of

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June 22, 2018. Progressive filed a motion for summary judgment on June 12, 2018, with a noting

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date of July 6, 2018.

STIPULATED MOTION AND ORDER AMENDING
SUMMARY JUDGMENT SCHEDULE (2:17-CV-00476MJP) - PAGE 1

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Pursuant to LCR 7(k), the parties have agreed to modify the current briefing schedule for

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their cross motions for summary judgment, and to allow plaintiff to combine her reply and response

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memoranda into a single extra-length brief. Accordingly, the parties agree and stipulate that good

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cause exists to modify the briefing schedule as follows:

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Progressive and CCS will file their responses to plaintiff’s motion for partial summary
judgment, which will not exceed 24 pages each, on June 20, 2018.
Plaintiff will file a combined response to Progressive’s motion for summary judgment and

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reply in support of plaintiff’s partial motion for summary judgment, which will not exceed 48 pages,

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on July 2, 2018.

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Progressive will file its reply in support of its motion for summary judgment (limited to
arguments I, II, and IV in Progressive’s motion), which will not exceed 12 pages, on July 6, 2018.
STIPULATED and AGREED:

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Dated this 13th day of June, 2018

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TOUSLEY BRAIN STEPHENS PLLC

BULLIVANT HOUSER BAILEY PC

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

By: /s/ Matthew J. Sekits
Matthew J. Sekits, WSBA #26175
E-mail: [e-mail]
Holly D. Brauchli, WSBA #44814
E-mail: [e-mail]

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IDE LAW OFFICE
Matthew James Ide, WSBA No. 26002
Email: [e-mail]
Attorney for Plaintiff Ayanna Rosenberg,
individually, and on Behalf of all those
similarly situated

Attorneys for Defendant
CCS Commercial, LLC
HOLLAND & KNIGHT
By: /s/ Kristin Asai
J. Matthew Donohue, WSBA No. 52455
Email: [e-mail]
Shannon Armstrong, WSBA No. 45947
Email: [e-mail]
Kristin Asai, WSBA No. 49511
Email: [e-mail]
Attorneys for Defendant Progressive Direct
Insurance Company

STIPULATED MOTION AND ORDER AMENDING
SUMMARY JUDGMENT SCHEDULE (2:17-CV-00476MJP) - PAGE 2

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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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briefing schedule for plaintiff’s motion for partial summary judgment and Progressive’s motion for

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summary judgment be amended as indicated. Plaintiff’s motion for partial summary judgment and

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Progressive’s motion for summary judgment shall both be noted for consideration on July 6, 2018.

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DATED this _14th_ day of ___June___, 2018.

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A
The Honorable Marsha J. Pechman
United States Senior District Court Judge

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STIPULATED MOTION AND ORDER AMENDING
SUMMARY JUDGMENT SCHEDULE (2:17-CV-00476MJP) - PAGE 3

CERTIFICATE OF SERVICE

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I hereby certify that I caused the foregoing STIPULATED MOTION AND [PROPOSED]
ORDER AMENDING SUMMARY JUDGMENT SCHEDULE to be served on the following
person[s]:
Chase Christian Alvord
James M. Bulthuis
Tousely Brain Stephens
1700 Seventh Avenue, Suite 2200
Seattle, WA 98101
[e-mail]
[e-mail]

Matthew J. Sekits
Holly D. Brauchli
Bullivant Houser Bailey PC
1700 Seventh Avenue, Ste. 1810
Seattle, WA 98101
[e-mail]
[e-mail]
Attorneys for Defendant CCS Commercial LLC

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

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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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

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

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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 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 June 13, 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
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