Williams v. Foremost Insurance Company Grand Rapids Michigan

Filing 26

ORDER granting 25 Stipulated Motion for a 2-Day Extension of the Discovery Deadline. The discovery deadline is moved to April 18, 2018 for the purpose of taking the deposition of Rebecca Cremin only. 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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TABITHA WILLIAMS, a person,

C17-1113 RSM

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Plaintiff,

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STIPULATION AND ORDER FOR 2-DAY
EXTENSION OF DISCOVERY
DEADLINE;

v.
FOREMOST INSURANCE COMPANY
GRAND RAPIDS MICHIGAN, an insurance
company.

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Defendant.

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I. STIPULATED REQUEST
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All parties respectfully request that the Court extend the discovery deadline for two days,
to April 18, 2018, for the deposition of Rebecca Cremin.
II. FACTS

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The parties have been working for several months to schedule the deposition of Rebecca

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Cremin. Ms. Cremin was John Blanchard’s supervisor and was one of the employees involved in

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the coverage denial in this matter. Counsel for both Plaintiff and Defendant both believed that

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Ms. Cremin lived in Washington state and that her deposition would be relatively easy to
schedule. However, counsel for Defendant later learned that she has moved to New Mexico. The

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parties also learned that the calendars of Ms. Cremin, Plaintiff counsel, and Defense counsel

STIPULATED MOTION AND ORDER — 1
2:17−cv−01113−RSM

JOEL B. HANSON
ATTORNEY AT LAW, PLLC
19909 BALLINGER WAY NE
SHORELINE, WA 98155
[e-mail]

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prevented them from being available to conduct her deposition in New Mexico until the week of

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April 18, 2018. Accordingly, counsel for both parties have arranged travel for her deposition on

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April 18. Presently, the discovery deadline in this case is April 16, 2018. (Dkt. No. 10.)
DATED this 20th day of March, 2018.

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JOEL B. HANSON, ATTORNEY AT LAW, PLLC

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__ /s/ Joel Hanson_______________________
Joel B. Hanson, WSBA #40814
Attorney for Plaintiff

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DATED this 20th day of March, 2018.

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LETHER & ASSOCIATES, PLLC

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___/s/ Eric Neal_____________________________
Thomas Lether, WSBA #18089
Eric J. Neal, WSBA #31863
1848 Westlake Avenue N, Suite 100
Seattle, WA 98109
P: [phone]
F: [phone]
[e-mail]
[e-mail]
Counsel for Defendant Foremost Insurance Company
Grand Rapids Michigan

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IT IS HEREBY ORDERED this 23rd day of March that the parties’ Stipulated Motion

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for a 2-Day Extension of the Discovery Deadline is GRANTED. The discovery deadline is moved

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to April 18, 2018 for the purpose of taking the deposition of Rebecca Cremin only.

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A

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RICARDO S. MARTINEZ
CHIEF UNITED STATES DISTRICT JUDGE

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STIPULATED MOTION AND ORDER — 2
2:17−cv−01113−RSM

JOEL B. HANSON
ATTORNEY AT LAW, PLLC
19909 BALLINGER WAY NE
SHORELINE, WA 98155
[e-mail]