International Brotherhood of Teamsters, Airline Division et al v. Alaska Air Group, Inc

Filing 70

STIPULATION AND ORDER setting briefing schedule for Defendants' 27 MOTION to Dismiss. Plaintiffs' supplemental opposition due 5/4/2018; Defendants' supplemental reply due 5/18/2018. Signed by Judge Marsha J. Pechman. (PM)

The Honorable Marsha Pechman

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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INTERNATIONAL BROTHERHOOD OF
TEAMSTERS, AIRLINE DIVISION,

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No. 2:17-cv-1327
and

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STIPULATION AND ORDER
AIRLINE PROFESSIONAL ASSOC. OF
THE INTERNATIONAL BROTHERHOOD
OF TEAMSTERS, LOCAL UNION NO.
1224,

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Plaintiffs,
v.

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ALASKA AIR GROUP, INC.
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and
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HORIZON AIR INDUSTRIES, INC.
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Defendants.

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The parties respectfully file this stipulation and proposed order to (1) propose a

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schedule for submitting supplemental briefs on the pending motion to dismiss; (2) request a

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stay of the other deadlines in the current case schedule, pending resolution of the pending

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motion; and (3) request oral argument on the pending motion to dismiss.

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STIPULATION AND ORDER - 1
2:17-cv-01327-MJP

Recitals

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1.

Plaintiffs filed their original complaint in this case on September 1, 2017, Dkt.

1, and their amended complaint on October 13, 2017. Dkt. 20.
2.

Defendants moved to dismiss the amended complaint. Dkt. 27. Plaintiffs

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opposed the motion and also moved to stay consideration of the motion pending the production

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of discovery the Court had previously ordered. Dkt. 32 (discovery order), 44 (motion to stay),

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51 (opposition to motion to dismiss).

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3.

The Court convened a status conference on February 1, 2018, to address the

management of discovery. Following the conference, the Court issued an order, dated February
6, 2018, regarding discovery and resolution of the pending motion to dismiss. Dkt. 67.
4.

After Defendants produced additional documents, on March 28, 2018, Plaintiffs

took the deposition of Defendant AAG pursuant to Fed. R. Civ. P. 30(b)(6).
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The parties expect to receive the transcript of that deposition on or around April

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11, 2018. Upon receipt of the transcript, the parties will be prepared to submit the supplemental

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briefing called for in the Court’s February 6, 2018, order.
Stipulation

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1.

Plaintiffs shall file their supplemental opposition to Defendants’ motion to

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dismiss, not to exceed ten pages (exclusive of exhibits), by no later than May 4, 2018.

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Defendants shall file their supplemental reply in support of their motion to dismiss, not to

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exceed ten pages (exclusive of exhibits), by no later than May 18, 2018.

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2.

The parties jointly request oral argument on the motion to dismiss.

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3.

The parties request that the deadlines set forth in the Court’s November 15,

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2017, Order Setting Trial Date & Related Dates, Dkt. 38, be stayed pending resolution of the

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pending motion to dismiss.

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4.

In the event that the Court does not dismiss the case in its entirety, the parties

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shall confer within two weeks of the Court’s order resolving the pending motion to dismiss to

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STIPULATION AND ORDER - 2
2:17-cv-01327-MJP

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discuss appropriate deadlines for trial and related dates. The parties shall then submit a joint

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report to the Court within two weeks of their conference proposing a new case schedule.

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DATED this 6th day of April, 2018.
/s/ Darin M. Dalmat
Kathleen Phair Barnard, WSBA No. 17896
Darin M. Dalmat, WSBA No. 51384
SCHWERIN CAMPBELL BARNARD
IGLITZIN& LAVITT LLP
18 Wet Mercer Street, Suite 400
Seattle, WA 98119
206-285-2828 (phone)
206-378-4132 (fax)
[e-mail]
[e-mail]

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Attorneys for Plaintiffs
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/s/ Taylor S. Ball
Mark A. Hutcheson, WSBA No. 1552
Taylor S. Ball, WSBA No. 46927
DAVIS WRIGHT TREMAINE LLP
1201 3rd Ave., Ste. 1700
Seattle, WA 98101-3045
206-622-3150 (phone)
206-757-7700 (fax)
[e-mail]
[e-mail]

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Douglas W. Hall, DC Bar No. 430406*
JONES DAY
51 Louisiana Avenue, N.W.
Washington, DC 20001
202-879-5432 (phone)
202-626-1700 (fax)
[e-mail]
*Admitted Pro Hac Vice

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Attorneys for Defendants

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STIPULATION AND ORDER - 3
2:17-cv-01327-MJP

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SO ORDERED.
Dated: April 13, 2018

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A

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Marsha J. Pechman
United States District Judge

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STIPULATION AND ORDER - 4
2:17-cv-01327-MJP