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

1
2
3
4
5

UNITED STATES DISTRICT COURT
WESTERN DIVISION OF WASHINGTON
AT SEATTLE

6
7
8

LISA MOORE, an individual,

No. 2:17-cv-00800 TSZ

Plaintiff,

9

JOINT STIPULATION AND ORDER
FOR TRIAL CONTINUANCE AND
NEW SCHEDULING ORDER

10

v.

11

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,

12
13
14

Defendants.

15
16

IT IS HEREBY STIPULATED by and between Beverly G. Grant and Jeffery D. Bradley

17

of Beverly Grant Law Firm, P.S., counsel for Plaintiff herein and Ethel Johnson, Karen Y. Cho,

18

M. Nicole Beckley of Morgan Lewis & Bockius, LLP and Laurence Shapero of Ogletree Deakins

19

Nash Smoak & Stewart, counsel for Defendants herein, that the trial of the above entitled matter

20

may be continued from November 4, 2019 to any date after July 31, 2020 and a proposed

21

continuance of remaining case deadlines as follows:

22

/ / /

23

/ / /

24
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
[phone]

1

Description

Current Dates

Proposed
Dates

2
3
4
5
6
7
8
9
10

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.

11

The primary reasons necessitating continuance are because the Plaintiff’s physician, Dr.

12

Soorani, of Los Angeles, CA, has indicated that Plaintiff’s mental state will be jeopardized if

13

her deposition were to be taken now and he requests that Plaintiff’s deposition be deferred at a

14

minimum of four (4) to six (6) months. Dr. Soorani further recommends that Plaintiff’s

15

deposition be broken into two days, rather than a full day. Further, Plaintiff’s counsel, Beverly

16

Grant, has only recently substituted in as counsel of record for Plaintiff, and Ms. Grant has

17

another trial scheduled for the same date as the trial in this matter. Ms. Grant’s other trial is

18

scheduled to commence on November 4, 2019, in the matter of Brown v. State of Washington,

19

et al, Case No. 3:18-cv-05647-RBL.

20

Based on Plaintiff’s counsel and Dr. Soorani’s representations about Plaintiff’s medical

21

condition and Plaintiff’s counsel’s conflict, the parties have agreed to: (1) accept the

22

recommendation by Plaintiff’s physician; (2) defer further discovery until Plaintiff’s deposition

23
24
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
[phone]

1

is taken; (3) limit discovery to the retaliation claim only; and (4) enter into good faith settlement

2

negotiations with the assistance of a mediator while waiting for Plaintiff to get well enough to

3

participate in the taking of her deposition.

4

Stipulated to this 10th day of July 2019.

5

BEVERLY GRANT LAW FIRM, P.S.

MORGAN LEWIS & BOCKIUS

6

By:
/s/ Ethel J. Johnson
Ethel J. Johnson, Texas Bar No. 10714050
1000 Louisiana Street, Suite 4000
Houston, TX 77002
[e-mail]
Tele: [phone]
Attorney for Defendants

10

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
[e-mail]
[e-mail]
Attorneys for Plaintiff

11

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: [phone]
[e-mail]
[e-mail]
Attorney for Defendants

By: /s/ Laurence A. Shapero
Laurence A. Shapero, WSBA No. 31301
1201 Third Avenue, Suite 5150
Seattle, WA 98101
[e-mail]
Tele: [phone]
Attorney for Defendants

7
8
9

12
13
14
15
16
17
ORDER
18
This matter having come by way of stipulation by counsel, it is HEREBY
19
ADJUDGED, DECREED and ORDERED that:
20
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.

21
22
23
24
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
[phone]

1
DATED this 15th day of July 2019.

A

2
3

Thomas S. Zilly
United States District Judge

4
5
6
7
8
9
10
11
12
13

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
[e-mail]
[e-mail]
Attorneys for Plaintiff

By:
/s/ Ethel J. Johnson
Ethel J. Johnson, Texas Bar No: 10714050
1000 Louisiana Street, Suite 4000
Houston, TX 77002
[e-mail]
Tele: [phone]
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: [phone]
[e-mail]
[e-mail]
Attorney for Defendants

By: /s/ Laurence A. Shapero
Laurence A. Shapero, WSBA No. 31301
1201 Third Avenue, Suite 5150
Seattle, WA 98101
[e-mail]
Tele: [phone]
Attorney for Defendants

14
15
16
17
18
19
20
21
22
23
24
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
[phone]