Costco Wholesale Corporation v. Arrowood Indemnity Company

Filing 21

STIPULATION AND ORDER to Continue Expert Witness Report Deadline re parties' 20 Stipulation; Expert Witness Reports due by 7/5/2018, by Judge Robert S. Lasnik. (SWT)

Honorable Robert S. Lasnik

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE
COSTCO WHOLESALE CORPORATION,
Plaintiff,
v.

Civil Action No. 2:17-cv-01212-RSL
STIPULATED MOTION AND ORDER TO
CONTINUE EXPERT WITNESS REPORT
DEADLINE

ARROWOOD INDEMNITY COMPANY,
Defendant.

Pursuant to LCR 7(d)(1) and LCR 10(g), Plaintiff Costco Wholesale Corporation
(“Costco”) and Defendant Arrowood Indemnity Company (“Arrowood”), by and through their
attorneys of record, hereby submit this Stipulated Motion and [Proposed] Order to Continue the
Expert Witness Report Deadline. The parties have met and conferred, and submit this Stipulated
Motion in good faith.
DISCUSSION
By its Minute Order Setting Trial Date & Related Dates (ECF No. 13), the Court set this
matter for trial on November 5, 2018 and also established a case schedule of pretrial deadlines.
On April 19, 2018, the Court entered the Parties’ first extension of time for certain pretrial
deadlines (ECF No. 19), including, among others, an extension of the deadline for expert witness
reports from May 9, 2018 to June 20, 2018.
To date, the Parties have engaged in substantial written discovery and have taken the
depositions of several party witnesses. Arrowood has taken the deposition of one of Costco’s

witnesses and Costco has taken the deposition of two of Arrowood’s witnesses. The Parties have
scheduled additional depositions in the case for June 14, 2018 and June 27, 2018. These
depositions may provide testimony for the Parties’ experts to rely upon in their respective reports.
In light of the upcoming depositions and expert witness report deadline in the case, the Parties
stipulate and jointly move the Court for a brief two-week continuance of the expert witness report
deadline for purposes of completing depositions to Thursday, July 5, 2018.
The Parties do not request that the Court continue the trial date or any other dates unless
specified herein. Accordingly, the Parties respectfully request that this Stipulated Motion be
approved and that the Court agree to continue the expert witness report deadline to Thursday,
July 5, 2018.
IT IS SO STIPULATED THIS 7th day of June, 2018.

DATED: June 7, 2018

CLYDE & CO US LLP

/s/ Alexander E. Potente
Alexander E. Potente, WSBA #48858
[e-mail]
601 Union Street, Two Union Square, 42nd Floor
Seattle, Washington 98101
Phone [phone]
Fax [phone]
Attorneys for Defendant
ARROWOOD INDEMNITY COMPANY

3855054
STIPULATED MOTION AND [PROPOSED] ORDER TO
CONTINUE EXPERT WITNESS REPORT DEADLINE (2:17-cv01212-RSL) -

CLYDE & CO US LLP
601 Union Street, Two Union Square, 42nd Floor
Seattle, Washington 98101
[phone]

DATED: June 7, 2018

PACIFICA LAW GROUP LLP

/s/ Paul J. Lawrence
Paul J. Lawrence, WSBA #13557
Matthew J. Segal, WSBA #29797
Nicholas W. Brown, WSBA #33586
1191 Second Avenue, Suite 2000
Seattle, WA 98101
Phone: [phone]
Fax: [phone]
Attorneys for Plaintiff
COSTCO WHOLESALE CORPORATION

3855054
STIPULATED MOTION AND [PROPOSED] ORDER TO
CONTINUE EXPERT WITNESS REPORT DEADLINE (2:17-cv01212-RSL) -

CLYDE & CO US LLP
601 Union Street, Two Union Square, 42nd Floor
Seattle, Washington 98101
[phone]

ORDER
IT IS HEREBY ORDERED that this Stipulated Motion to continue the expert witness
report deadline is GRANTED. The new date for the expert witness report deadline is Thursday,
July 5, 2018.

DATED this 8th day of June, 2018.

A
Honorable Robert S. Lasnik
United States District Judge

3855054
STIPULATED MOTION AND [PROPOSED] ORDER TO
CONTINUE EXPERT WITNESS REPORT DEADLINE (2:17-cv01212-RSL) -

CLYDE & CO US LLP
601 Union Street, Two Union Square, 42nd Floor
Seattle, Washington 98101
[phone]