Emmanuel et al v. King County et al

Filing 90

ORDER granting Parties' 86 Stipulated Motion for Extension of Time to Complete Discovery. Discovery completed by 8/17/2020. Signed by Judge James L. Robart.(LH)

Case 2:18-cv-00377-JLR Document 86 Filed 07/30/20 Page 1 of 4
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The Honorable James L. Robart

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UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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RICHARD HOMCHICK,

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v.
KING COUNTY, a home rule charter county and
municipal corporation doing business as the
KING COUNTY SHERIFF’S OFFICE and the
KING COUNTY PROSECUTING
ATTORNEY’S OFFICE; JOHN URQUHART,
individually and in his official capacity as King
County Sheriff; DANIEL SATTERBERG,
individually and in his official capacity as King
County Prosecutor,

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STIPULATION AND ORDER FOR
A LIMITED EXTENSION TO
DISCOVERY DEADLINE TO
ACCOMMODATE SELECT
DEPOSITIONS
Noted for Consideration:
July 30, 2020

Defendants.

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No. C18-00377-JLR

Plaintiff,

STIPULATION
The parties hereby jointly seek permission from the Court to conduct select
depositions after the upcoming August 3, 2020, discovery deadline, given certain complications
related to scheduling as set forth below.
Under the current schedule, the deadline to complete discovery in this matter is
August 3, 2020. Dkt. #53. However, there are a small number of depositions remaining that,
despite best efforts, the parties are unable to complete by the deadline due primarily to witness
unavailability.

STIPULATION AND ORDER FOR A LIMITED
EXTENSION TO DISCOVERY DEADLINE TO
ACCOMMODATE SELECT DEPOSITIONS – Page 1

BAILEY DUQUETTE P.C.
500 UNION STREET, SUITE 800
SEATTLE, WASHINGTON 98101
T 206.225.2250 | F 866.233.5869

Case 2:18-cv-00377-JLR Document 86 Filed 07/30/20 Page 2 of 4
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Specifically, Defendants seek to depose Plaintiff’s expert, Lauren Freeman, who

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produced her final report on July 3, 2020, in compliance with the expert disclosure deadline.

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See Dkt. #57. Because Ms. Freeman was not available during the latter part of July when

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Defendants sought to take her deposition, the parties have agreed, pending the Court’s approval,

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to hold Ms. Freeman’s deposition on August 6, 2020, i.e., three days after the current cut-off.

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Likewise, Plaintiff has sought for the last two months to schedule a deposition of non-

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party Demand Abolition through its counsel. After initial indications that the Demand Abolition

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witness would be available in July and that dates would be provided for that deposition in that

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timeframe, Plaintiff was informed on July 13, 2020, that the witness had departed for a vacation

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and would not return until the week of August 3, 2020. That deposition is now tentatively

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scheduled for August 11, 2020.

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Finally, Plaintiff informed Defendants last month about the potential need to conduct

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one or two depositions after Plaintiff received a supplemental production of documents then-

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anticipated from the Sheriff’s Office. Last Friday, Plaintiff received approximately 26,000

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pages of emails. Plaintiff is diligently reviewing those documents to ascertain the need and

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timing for depositions(s), but, given the volume of materials and competing obligations, as well

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as witness availability issues, any such deposition(s) unfortunately cannot be realistically

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completed by August 3, 2020. A limited two-week extension will allow for the parties to

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coordinate scheduling that deposition(s) and to resolve any other attendant issues.

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For the above-stated reasons, the parties respectfully request that the Court enter the

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below Order, extending the discovery deadline by no more than two weeks to August 17, 2020.

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Such an extension should not impact any other deadlines on the current case schedule.

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STIPULATION AND ORDER FOR A LIMITED
EXTENSION TO DISCOVERY DEADLINE TO
ACCOMMODATE SELECT DEPOSITIONS – Page 2

BAILEY DUQUETTE P.C.
500 UNION STREET, SUITE 800
SEATTLE, WASHINGTON 98101
T 206.225.2250 | F 866.233.5869

Case 2:18-cv-00377-JLR Document 86 Filed 07/30/20 Page 3 of 4
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STIPULATED AND AGREED TO this 30th day of July, 2020.

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Respectfully Submitted,

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BAILEY DUQUETTE P.C.

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KING COUNTY PROSECUTING
ATTORNEY’S OFFICE

By: /s/ Hozaifa Y. Cassubhai
Hozaifa Y. Cassubhai, WSBA #39512
500 Union Street, Suite 800
Seattle, Washington 98101
Telephone: [phone]
Email: [e-mail]

By: /s/ David Hackett
David Hackett, WSBA #21236
Amy Montgomery, WSBA #32068
900 King County Administration Bldg.
500 Fourth Avenue
Seattle, Washington 98104
Telephone: [phone]
Email: [e-mail]
[e-mail]

Attorneys for Plaintiff Richard Homchick

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Attorneys for Defendants King County
Prosecuting Attorney’s Office, King County
Sheriff’s Office, Daniel Satterberg, and
John Urquhart

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ORDER

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The Court’s scheduling order (Dkt. #53) is amended as follows:

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Current Date
Discovery Deadline

New Date

August 3, 2020

August 17, 2020

IT IS SO ORDERED.
DATED this 13th day of August, 2020.

A

___________________________________
THE HONORABLE JAMES L. ROBART
UNITED STATES DISTRICT COURT

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STIPULATION AND [PROPOSED] ORDER FOR A
LIMITED EXTENSION TO DISCOVERY DEADLINE
TO ACCOMMODATE SELECT DEPOSITIONS – Page 3

BAILEY DUQUETTE P.C.
500 UNION STREET, SUITE 800
SEATTLE, WASHINGTON 98101
T 206.225.2250 | F 866.233.5869

Case 2:18-cv-00377-JLR Document 86 Filed 07/30/20 Page 4 of 4
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CERTIFICATE OF FILING AND SERVICE

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I hereby certify that, on July 30, 2020, I electronically filed the foregoing document

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with the Clerk of the Court using the CM/ECF System, which will send notification of such

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filing to those attorneys of record registered on the CM/ECF system.

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Dated this July 30, 2020.
BAILEY DUQUETTE P.C.
By /s Hozaifa Y. Cassubhai
Hozaifa Y. Cassubhai, WSBA#39512
500 Union Street, Suite 800
Seattle, Washington 98101
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
Attorney for Plaintiff Richard Homchick

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STIPULATION AND [PROPOSED] ORDER FOR A
LIMITED EXTENSION TO DISCOVERY DEADLINE
TO ACCOMMODATE SELECT DEPOSITIONS – Page 4

BAILEY DUQUETTE P.C.
500 UNION STREET, SUITE 800
SEATTLE, WASHINGTON 98101
T 206.225.2250 | F 866.233.5869