Senior Housing Assistance Group v. AMTAX Holdings 260, LLC et al

Filing 75

STIPULATION AND ORDER to Continue Trial Date and Related Deadlines re parties' 74 Stipulation: Jury Trial is CONTINUED to 2/19/2019 at 09:00 AM before Judge Ricardo S. Martinez. Expert Witness Disclosure/Reports under FRCP 26(a)(2) du e by 9/7/2018, Motions due by 9/24/2018, Discovery completed by 10/22/2018, Dispositive motions due by 11/21/2018, 39.1 Settlement Report due by 1/7/2019, Motions in Limine due by 1/22/2019, Pretrial Order due by 2/7/2019, Attorney settlement conference to be held by 2/14/2019, Trial briefs to be submitted by 2/14/2019. Signed by Judge Ricardo S. Martinez. (SWT)

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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SENIOR HOUSING ASSISTANCE
GROUP,
Plaintiff,

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v.

No. 2:17-cv-01115-RSM
STIPULATION AND ORDER TO
CONTINUE TRIAL DATE AND
RELATED DATES

AMTAX HOLDINGS 260, LLC, et al.,
Defendants.

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AMTAX HOLDINGS 260, LLC, et al.,
Counter-Plaintiffs,

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v.

SENIOR HOUSING ASSISTANCE
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Counter-Defendants.

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STIPULATION AND ORDER TO
CONTINUE TRIAL DATE AND RELATED
DATES
(No. 2:17-cv-01115-RSM) –1

Perkins Coie LLP

1201 Third Avenue, Suite 4900
Seattle, WA 98101-3099
Phone: [phone]
Fax: [phone]

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Plaintiff and Counter-Defendant Senior Housing Assistance Group; Defendants

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AMTAX/Protech AMTAX Holdings 260, LLC, Protech Holdings W, LLC, AMTAX Holdings

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259, LLC, AMTAX Holdings 261, LLC, AMTAX Holdings 258, LLC, AMTAX Holdings 257,

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LLC, AMTAX Holdings 164, LLC, Protech 2002-A, LLC, AMTAX Holdings 109, LLC, and

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Protech 2001-B, LLC; and Counter-Defendants Senior Housing Assistance Corporation, Steel

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Lake Enterprises, LLC, Lakewood Meadows Enterprises, LLC, Lynnwood Retirement Living,

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LLC, and Woodlands Associates, LLC (collectively the “Parties”), by and through their counsel

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of record, stipulate and agree as follows:

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WHEREAS, the Court entered a scheduling order on October 11, 2017 (the “Scheduling
Order”) setting forth a trial date and related dates;

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WHEREAS, the Scheduling Order provides that the trial will begin on January 15, 2019;

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WHEREAS, on June 25, 2018, the Court extended the deadline for disclosure of expert

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testimony under Federal Rule of Civil Procedure 26(a)(2) from July 19, 2018 to August 20,

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2018;

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WHEREAS, in light of scheduling issues that have arisen, the Parties desire a further
continuance of the expert disclosure deadline from August 20, 2018 to September 7, 2018;

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WHEREAS, the Parties also desire to extend the trial date and related dates to

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accommodate the later expert disclosure deadline and to ensure adequate time to prepare any

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motions related to discovery, dispositive motions, and motions in limine;

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THEREFORE, subject to the approval of the Court, the Parties hereby stipulate and agree
that:


The deadline for disclosure of expert testimony under FRCP 26(a)(2) provided for in

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the Court’s June 25, 2018 order shall be continued from August 20, 2018 to

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September 7, 2018;

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

The deadline for filing motions related to discovery shall be continued from August
20, 2018 to September 24, 2018;

STIPULATION AND ORDER TO
CONTINUE TRIAL DATE AND RELATED
DATES
(No. 2:17-cv-01115-RSM) –2

Perkins Coie LLP

1201 Third Avenue, Suite 4900
Seattle, WA 98101-3099
Phone: [phone]
Fax: [phone]

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

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2018 to October 22, 2018;


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



The deadline for filing motions in limine shall be continued from December 18, 2018
to January 22, 2019;



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The deadline for mediation per Local Civil Rule 29.1(c)(3), if requested, shall be
continued from December 3, 2018 to January 7, 2019;

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The deadline for filing dispositive motions shall be continued from October 17, 2018
to November 21, 2018;

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The deadline for completion of discovery shall be continued from September 17,

The deadline for filing an agreed pretrial order shall be continued from January 3,
2019 to February 7, 2019;



The deadline for filing Trial briefs, proposed voir dire questions, jury instructions,

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neutral statement of the case, and trial exhibits shall be continued from January 10,

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2019 to February 14, 2018; and

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

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RESPECTFULLY SUBMITTED this 15th day of August 2018.

The trial date shall be continued from January 15, 2019 to February 19, 2019.

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Perkins Coie LLP

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By: /s/ Steven D. Merriman
David J. Burman, WSBA #10611
Steven D. Merriman, WSBA #44035
1201 Third Avenue, Suite 4900
Seattle, WA 98101-3099
Telephone: [phone]
Facsimile: 206.359.9000
Email: [e-mail]
[e-mail]

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Boies Schiller Flexner LLP

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Christopher Caldwell, admitted pro hac vice
Eric Pettit, admitted pro hac vice
725 S Figueroa Street, 31st Floor
Los Angeles, CA 90017
Telephone: [phone]
Facsimile: 213 629 9022

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STIPULATION AND ORDER TO
CONTINUE TRIAL DATE AND RELATED
DATES
(No. 2:17-cv-01115-RSM) –3

Perkins Coie LLP

1201 Third Avenue, Suite 4900
Seattle, WA 98101-3099
Phone: [phone]
Fax: [phone]

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Email: [e-mail]
[e-mail]

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Attorneys for AMTAX/Protech AMTAX
Holdings 260, LLC, Protech Holdings W, LLC,
AMTAX Holdings 259, LLC, AMTAX
Holdings 261, LLC, AMTAX Holdings 258,
LLC, AMTAX Holdings 257, LLC, AMTAX
Holdings 164, LLC, Protech 2002-A, LLC,
AMTAX Holdings 109, LLC, and Protech
2001-B, LLC

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Hillis Clark Martin & Peterson, P.S.

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By: s/ Jake Ewart
Jake Ewart, WSBA #38655
Jessica C. Kerr, WSBA #49866
999 Third Avenue, Suite 4600
Seattle, WA 98104
Telephone: [phone]
Facsimile: 206.623.7789
Email: [e-mail]
[e-mail]

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Attorneys for Senior Housing Assistance Group
and Senior Housing Assistance Corporation

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Karr Tuttle Campbell

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By: /s/ Dennis H. Walters
Dennis H. Walters, WSBA #9444
701 Fifth Avenue, Suite 3300
Seattle, WA 98104
Telephone: [phone]
Facsimile: 203.682.7100
Email: [e-mail]

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Attorney for Steel Lake Enterprises, LLC;
Lakewood Meadows Enterprises, LLC;
Lynnwood Retirement Living, LLC; and
Woodlands Associates, LLC

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IT IS SO ORDERED this 16th day of August 2018.

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RICARDO S. MARTINEZ
CHIEF UNITED STATES DISTRICT JUDGE

STIPULATION AND ORDER TO
CONTINUE TRIAL DATE AND RELATED
DATES
(No. 2:17-cv-01115-RSM) –4

Perkins Coie LLP

1201 Third Avenue, Suite 4900
Seattle, WA 98101-3099
Phone: [phone]
Fax: [phone]