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)

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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 (253) 252-5454 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 (253) 252-5454 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 Ethel.johnson@morganlewis.com Tele: (713) 890-5191 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 Beverly@BevGrantlaw.com JefferyBradley@BevGrantlaw.com 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: (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 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 (253) 252-5454 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 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 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 (253) 252-5454

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