Moore v. The Boeing Company et al
Filing
87
STIPULATION AND ORDER for Trial Continuance and New Scheduling Order re parties' 86 Stipulation: Jury Trial is set for 8/24/2020. Expert Discovery Cutoff is 4/10/2020, Motions related to expert witnesses due by 4/23/2020, Motions due by 2/6/2020, Discovery completed by 3/12/2020, Dispositive motions due by 4/16/2020, Motions in Limine due by 7/23/2020, Pretrial Order due by 8/7/2020, Pretrial Conference set for 8/14/2020 at 1:30 PM in Courtroom 15206 before Judge Thomas S. Zilly. Rebuttal Expert Disclosure/Reports due by 3/26/2020, Trial briefs to be submitted by 8/7/2020, Proposed voir dire/jury instructions due by 8/7/2020. Signed by Judge Thomas S. Zilly. (SWT)
Honorable Thomas S. Zilly
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UNITED STATES DISTRICT COURT
WESTERN DIVISION OF WASHINGTON
AT SEATTLE
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LISA MOORE, an individual,
No. 2:17-cv-00800 TSZ
Plaintiff,
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JOINT STIPULATION AND ORDER
FOR TRIAL CONTINUANCE AND
NEW SCHEDULING ORDER
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v.
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THE BOEING COMPANY, a Delaware
Corporation; BOEING DEFENSE SPACE &
SECURITY, a division of BOEING, business
entity, form unknown; BOEING NETWORK
& SPACE SYSTEMS, a part of BOEING
DEFENSE, SPACE & SECURITY, a business
entity, form unknown, and DOES 1-10,
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Defendants.
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IT IS HEREBY STIPULATED by and between Beverly G. Grant and Jeffery D. Bradley
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of Beverly Grant Law Firm, P.S., counsel for Plaintiff herein and Ethel Johnson, Karen Y. Cho,
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M. Nicole Beckley of Morgan Lewis & Bockius, LLP and Laurence Shapero of Ogletree Deakins
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Nash Smoak & Stewart, counsel for Defendants herein, that the trial of the above entitled matter
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may be continued from November 4, 2019 to any date after July 31, 2020 and a proposed
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continuance of remaining case deadlines as follows:
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/ / /
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/ / /
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JOINT STIPULATION AND ORDER
FOR TRIAL CONTINUANCE AND
NEW SCHEDULING ORDER
DB2/ 36896630.1
Page 1 of 4
5808 100th Street SW, Suite A
Lakewood, WA 98499
(253) 252-5454
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Description
Current Dates
Proposed
Dates
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Discovery Motions
deadline
Discovery Completed by
Rebuttal Expert Deadline
Expert Discovery Cutoff
Dispositive motions
deadline
Deadline for filing motions
related to expert testimony
(e.g., Daubert motions)
Motion in limine deadline
Agreed pretrial order due
Voir dire/jury instructions/
trial briefs
Pretrial conference
New Dates By
Order of the
Judge
February 6, 2020
July 8, 2019
July 26, 2019
August 9, 2019
August 8, 2019
March 12, 2020
March 26, 2020
April 10, 2020
April 17, 2020
March 12, 2020
March 26, 2020
April 10, 2020
April 16, 2020
August 22, 2019
May 1, 2020
April 23, 2020
October 1, 2019
October 15, 2019
October 15, 2019
June 12, 2020
June 26, 2020
June 26, 2020
July 23, 2020
August 7, 2020
August 7, 2020
October 25, 2019
at 11:00 am
TBD
August 14, 2020
at 1:30 p.m.
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The primary reasons necessitating continuance are because the Plaintiff’s physician, Dr.
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Soorani, of Los Angeles, CA, has indicated that Plaintiff’s mental state will be jeopardized if
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her deposition were to be taken now and he requests that Plaintiff’s deposition be deferred at a
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minimum of four (4) to six (6) months. Dr. Soorani further recommends that Plaintiff’s
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deposition be broken into two days, rather than a full day. Further, Plaintiff’s counsel, Beverly
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Grant, has only recently substituted in as counsel of record for Plaintiff, and Ms. Grant has
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another trial scheduled for the same date as the trial in this matter. Ms. Grant’s other trial is
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scheduled to commence on November 4, 2019, in the matter of Brown v. State of Washington,
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et al, Case No. 3:18-cv-05647-RBL.
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Based on Plaintiff’s counsel and Dr. Soorani’s representations about Plaintiff’s medical
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condition and Plaintiff’s counsel’s conflict, the parties have agreed to: (1) accept the
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recommendation by Plaintiff’s physician; (2) defer further discovery until Plaintiff’s deposition
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JOINT STIPULATION AND ORDER
FOR TRIAL CONTINUANCE AND
NEW SCHEDULING ORDER
DB2/ 36896630.1
Page 2 of 4
5808 100th Street SW, Suite A
Lakewood, WA 98499
(253) 252-5454
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is taken; (3) limit discovery to the retaliation claim only; and (4) enter into good faith settlement
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negotiations with the assistance of a mediator while waiting for Plaintiff to get well enough to
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participate in the taking of her deposition.
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Stipulated to this 10th day of July 2019.
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BEVERLY GRANT LAW FIRM, P.S.
MORGAN LEWIS & BOCKIUS
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By:
/s/ Ethel J. Johnson
Ethel J. Johnson, Texas Bar No. 10714050
1000 Louisiana Street, Suite 4000
Houston, TX 77002
Ethel.johnson@morganlewis.com
Tele: (713) 890-5191
Attorney for Defendants
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By: /s/ Beverly G. Grant
Beverly G. Grant, WSBA No. 8034
Jeffery D. Bradley, WSBA No. 27726
5808 100th Street SW, Ste. A
Lakewood, WA 98499
Tele: 253-252-5454
Beverly@BevGrantlaw.com
JefferyBradley@BevGrantlaw.com
Attorneys for Plaintiff
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MORGAN LEWIS & BOCKIUS
OGLETREE DEAKINS NASH
SMOAK & STEWART
By: /s/ Karen Y. Cho
Karen Y. Cho, CA Bar No. 274810
Maureen N. Beckley, CA Bar 316754
One Market, Spear Street Tower
San Francisco, CA 94105
Tele: (415) 442-1210
Karen.cho@morganlewis.com
Maureen.beckley@morganlewis.com
Attorney for Defendants
By: /s/ Laurence A. Shapero
Laurence A. Shapero, WSBA No. 31301
1201 Third Avenue, Suite 5150
Seattle, WA 98101
Laurence.shapero@ogletree.com
Tele: (206) 876-5301
Attorney for Defendants
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ORDER
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This matter having come by way of stipulation by counsel, it is HEREBY
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ADJUDGED, DECREED and ORDERED that:
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1).
The Motion for Stipulation for Trial Continuance, docket no. 86, is Granted;
2).
The trial in this matter shall be set for August 24, 2020;
3).
The case schedule deadlines are continued as listed above.
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JOINT STIPULATION AND ORDER
FOR TRIAL CONTINUANCE AND
NEW SCHEDULING ORDER
DB2/ 36896630.1
Page 3 of 4
5808 100th Street SW, Suite A
Lakewood, WA 98499
(253) 252-5454
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DATED this 15th day of July 2019.
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Thomas S. Zilly
United States District Judge
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Presented by:
Approved as to form:
BEVERLY GRANT LAW FIRM, P.S.
MORGAN LEWIS & BOCKIUS
By: /s/ Beverly G. Grant
Beverly G. Grant, WSBA No. 8034
Jeffery D. Bradley, WSBA No. 27726
5808 100th Street SW, Ste. A
Lakewood, WA 98499
Tele: 253-252-5454
Beverly@BevGrantlaw.com
JefferyBradley@BevGrantlaw.com
Attorneys for Plaintiff
By:
/s/ Ethel J. Johnson
Ethel J. Johnson, Texas Bar No: 10714050
1000 Louisiana Street, Suite 4000
Houston, TX 77002
Ethel.johnson@morganlewis.com
Tele: (713) 890-5191
Attorney for Defendants
MORGAN LEWIS & BOCKIUS
OGLETREE DEAKINS NASH
SMOAK & STEWART
By: /s/ Karen Y. Cho
Karen Y. Cho, CA BAR No., 274810
Maureen N. Beckley, CA Bar 316754
One Market, Spear Street Tower
San Francisco, CA 94105
Tele: (415) 442-1210
Karen.cho@morganlewis.com
Maureen.beckley@morganlewis.com
Attorney for Defendants
By: /s/ Laurence A. Shapero
Laurence A. Shapero, WSBA No. 31301
1201 Third Avenue, Suite 5150
Seattle, WA 98101
Laurence.shapero@ogletree.com
Tele: (206) 876-5301
Attorney for Defendants
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JOINT STIPULATION AND ORDER
FOR TRIAL CONTINUANCE AND
NEW SCHEDULING ORDER
DB2/ 36896630.1
Page 4 of 4
5808 100th Street SW, Suite A
Lakewood, WA 98499
(253) 252-5454
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