Hernandez v. Experian Information Solutions Inc

Filing 16

ORDER granting 15 Stipulated Motion Extending Pretrial Deadlines and to Continue Trial Date. Discovery completed by 2/19/2017, Dispositive motions due by 3/13/2018, 39.1 mediation to be completed by 5/4/2018. Plaintiff's counsel to contact Court's in-court deputies within 10 days of order with proposed, agreed trial dates. Signed by Judge Ricardo S Martinez. (PM)

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON AT SEATTLE

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Omar Martinez Hernandez,

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Plaintiff,

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Case No. 2:17-cv-00722-RSM
UNOPPOSED STIPULATED MOTION
AND ORDER EXTENDING PRETRIAL
DEADLINES AND TO CONTINUE
TRIAL DATE

v.
Experian Information Solutions, Inc.,
Defendant.

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STIPULATION

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1.

Plaintiff Omar Martinez Hernandez (“Plaintiff”) and Defendant Experian

Information Solutions, Inc. (“Experian”) (collectively, “the Parties”), by and through their
attorneys of record, file this unopposed motion and agree to stipulate to extend the current pretrial
and trial deadlines listed in the June 26, 2017 scheduling order.
2.

Good cause exists for the requested extension of the pretrial deadlines and the trial

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date. The parties have been working diligently to complete discovery in this matter. However,

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Experian’s counsel experienced a major medical emergency for one of her children which has

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hindered the parties abilities to complete all discovery. Despite this hardship, the Parties have

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served and responded to written discovery requests and have also produced numerous documents.

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The Parties are also in the midst of discussing settlement and are hopeful that they may be able to

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reach a resolution prior to incurring the costs associated with conducting depositions.

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3.

As such, the Parties respectfully request the following extensions in the case:
a.

Discovery deadline extended from December 18, 2017 until
February 19, 2018;

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UNOPPOSED STIPULATED MOTION AND [PROPOSED]
ORDER EXTENDING PRETRIAL DEADLINES etc.
Case No. 2:17-cv-00722-RSM

JONES DAY
3161 Michelson Drive, Suite 800, Irvine, CA 92612
Telephone [phone]

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b.

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Deadline for dispositive motions to be filed from January 16, 2018 until
March 13, 2018;

c.

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Deadline to hold Mediation, if requested by the parties, from March 2,
2018 until May 4, 2018;

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d.

Deadline for Motions in Limine to a date appropriate to the new trial date;

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e.

Deadline to file Pretrial Order to a date appropriate to the new trial date;

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f.

Pretrial Conference changed to a date appropriate to the new trial date;

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g.

Trial Briefs changed to a date appropriate to the new trial date;

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h.

Proposed voir dire/jury instruction date will be changed to a date

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appropriate to a new trial date.
5. The Parties also stipulate to a continuance of the present trial date to a new date in
accordance with the above schedules.
6. The Parties propose rescheduling the trial date for some time in June or July, 2018.

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DATED: December 15, 2017

DATED: December 15, 2017

ROBERT S. SOLA, P.C.

JONES DAY

By: /s/ Robert S. Sola
Robert S. Sola
Admitted Pro Hac Vice
1500 SW First Avenue, Suite 800
Portland, OR 97201
Telephone: [phone]

By: /s/ Angela M. Taylor
Angela M. Taylor, CASBN 210425
Admitted Pro Hac Vice
3161 Michelson Drive, Suite 800
Irvine, CA 92612
Telephone: [phone]

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Christopher E. Green, WSBA 19410
Green LawFirm
225 106th Ave NE
Bellevue, WA 98004
Telephone: [phone]

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By: /s/ Rachel L. Dunnington
Rachel L. Dunnington, WSBA No. 47021
STOEL RIVES LLP
600 University Street, Suite 3600
Seattle, WA 98101
Telephone: [phone]

Attorneys for Plaintiff

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Attorneys for Defendant
EXPERIAN INFORMATION SOLUTIONS,
INC.

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UNOPPOSED STIPULATED MOTION AND ORDER
EXTENDING PRETRIAL DEADLINES etc.
Case No. 2:17-cv-00722-RSM

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JONES DAY
3161 Michelson Drive, Suite 800, Irvine, CA 92612
Telephone [phone]

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ORDER

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THIS MATTER came before the Court on the foregoing stipulation of the parties. The

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Court has reviewed the parties’ stipulation and, finding that the same is made for good cause, the

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Court hereby

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ORDERS that the current pretrial deadlines shall each be extended as follows:

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a.

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Discovery deadline extended from December 18, 2017 until
February 19, 2018;

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b.

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Deadline for dispositive motions to be filed from January 16, 2018 until
March 13, 2018;

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c.

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Deadline to hold Mediation, if requested by the parties, from March 2,
2018 until May 4, 2018;

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d.

Deadline for Motions in Limine to a date appropriate to the new trial date;

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e.

Deadline to file Pretrial Order to a date appropriate to the new trial date;

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f.

Pretrial Conference changed to a date appropriate to the new trial date;

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g.

Trial Briefs changed to a date appropriate to the new trial date;

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h.

Proposed voir dire/jury instruction date will be changed to a date

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appropriate to a new trial date.

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ORDERS that the trial date shall be continued in accordance with the above schedule;
and the Court further

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ORDERS that Plaintiff’s counsel shall contact the Court’s in-court Deputies, Laurie

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Cuaresma and Lowell Williams, at [e-mail] and

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[e-mail], within ten (10) days of the date of this Order with several

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proposed, agreed trial dates in this matter, after which the Court will issue an Amended

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Scheduling Order.

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IT IS SO ORDERED.

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///

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///

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UNOPPOSED STIPULATED MOTION AND ORDER
EXTENDING PRETRIAL DEADLINES etc.
Case No. 2:17-cv-00722-RSM

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JONES DAY
3161 Michelson Drive, Suite 800, Irvine, CA 92612
Telephone [phone]

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DATED this 18th day of December, 2017.

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A

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RICARDO S. MARTINEZ
CHIEF UNITED STATES DISTRICT JUDGE

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Presented by:

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JONES DAY

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_/s/ Angela M. Taylor
Angela M. Taylor, CASB No. 210425
[e-mail]
Admitted Pro Hac Vice
3631 Michelson Drive, Ste 800
Irvine, CA 92612
Telephone [phone]
Facsimile [phone]
Attorneys for Defendant
EXPERIAN INFORMATION SOLUTIONS, INC.

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UNOPPOSED STIPULATED MOTION AND ORDER
EXTENDING PRETRIAL DEADLINES etc.
Case No. 2:17-cv-00722-RSM

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JONES DAY
3161 Michelson Drive, Suite 800, Irvine, CA 92612
Telephone [phone]