Padilla et al v. US Immigration and Customs Enforcement et al
Filing
81
STIPULATION AND ORDER Regarding Exchange of Initial Disclosures and Submission of 26(f) Report re parties' 79 Stipulated Motion. The parties shall exchange initial disclosures by November 5, 2018. The parties shall submit their 26(f) report by November 12, 2018. Signed by Judge Marsha J. Pechman. (TH)
Case 2:18-cv-00928-MJP Document 81 Filed 10/15/18 Page 1 of 5
Case 2:18-cv-00928-MJP Document 79 Filed 10/11/18 Page 1 of 5
The Honorable Marsha J. Pechman
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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE
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YOLANY PAD ILLA, on behalf of herself and her
6-year-old son J.A.; IBIS GUZMAN, on behalf of herself
and her 5-year-old son R.G.; BLANCA ORANTES, on
behalf of herself and her 8-year-old son A.M.; BALTAZAR
VASQUEZ, on behalf of himself;
Plaintiffs-Petitioners,
v.
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U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT
("ICE");
U.S.
DEPARTMENT OF
HOMELAND
SECURITY ("DHS"); U.S. CUSTOMS AND BORDER
PROTECTION ("CBP"); U.S. CITIZENSHIP AND
IMMIGRATION SERVICES ("USCIS"); EXECUTIVE
OFFICE FOR IMMIGRATION REVIEW ("EOIR");
THOMAS HOMAN, Acting Director of ICE; KIRSTJEN
NIELSEN, Secretary of DHS; KEVIN K. McALEENAN,
Acting Commissioner of CBP; L. FRANCIS CISSNA,
Director of USCIS; MARC J. MOORE, Seattle Field Office
Director,
ICE,
JEFFERSON
BEAUREGARD
SESSIONS III, United States Attorney General; LOWELL
CLARK, warden of the Northwest Detention Center in
Tacoma, Washington; CHARLES INGRAM, warden of the
Federal Detention Center in SeaTac, Washington; DAVID
SHINN, warden of the Federal Correctional Institute in
Victorville, California; JAMES JANECKA, warden of the
Adelanto Detention Facility;
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No. 2:18-cv-928 MJP
JOINT STIPULATION
AND·-··
ORDER REGARDING
EXCHANGE OF INITIAL
DISCLOSURES AND
SUBMISSION OF 26(f)
REPORT
Defendants-Respondents.
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NOTE ON MOTION
CALENDAR: OCTOBER
11, 2018.
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JOINT STIPULATION AND
• ii I Ill ORDER
REGARDING EXCHANGE OF
INITIAL DISCLOSURES AND
SUBMISSION OF 26(f)
REPORT- 1
r'<.t"1T""-,..lr.
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°AKTTI
Northwest Immigrant Rights Project
615 Second Ave., Ste. 400
Seattle, WA 98104
Telephone (206) 957-8611
Case 2:18-cv-00928-MJP Document 81 Filed 10/15/18 Page 2 of 5
Case 2:18-cv-00928-MJP Document 79 Filed 10/11/18 Page 2 of 5
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Pursuant to Local Civil Rules 7(d)(l) and lO(g), Plaintiffs and Defendants hereby
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stipulate and jointly move the Court for an Order extending the deadline for the exchange of
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initial disclosures and the filing of the Fed. R. Civ. P. 26(f) report.
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On July 31, 2018, this Court entered an order setting the deadlines or the parties to meet
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and confer pursuant to Fed. R. Civ. P. 26(f), and to exchange initial disclosures and file a 26(f)
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report. ECF 17. The parties jointly determined that it was prudent to brief the issues in the
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motion to dismiss and motion for class certification prior to having a Rule 26(f) conference so
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that both parties had a fuller understanding of the issues. Pursuant to the instructions in that
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order, the parties jointly telephoned the Courtroom Deputy to request an extension. A thirty-day
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extension was granted. ECF 32.
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The parties have met and conferred pursuant to this Court's order. However, after the
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conference, the parties agreed that additional time to discuss would be productive, and would
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lead to the submission of a 26(f) report that would be more useful to the Court. Accordingly, the
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parties jointly request an additional 30-day extension of the deadline to exchange initial
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disclosures and submit a Rule 26(f) report to the Court.
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RESPECTFULLY SUBMITTED this 11th day of October, 2018.
s/ Matt Adams
Matt Adams, WSBA No. 28287
Email: matt@nwirp.org
Kristin Macleod-Ball*
Trina Realmuto*
Glenda M. Aldana Madrid, WSBA No. 46987
Email: glcnda@nwirp.org
AMERICAN IMMIGRATION
COUNCIL
100 Summer Street, 23rd Floor
Boston, MA 02110
(857) 305-3600
trealmuto@immcouncil.org
kmacleod-ball@immcouncil.org
Leila Kang, WSBA No. 48048
Email: lcila@nwirp.org
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NOR Tl !WEST IMMIGRANT
RIGHTS PROJECT
615 Second Avenue, Suite 400
Seattle, \VA 98104
Telephone: (206) 957-8611
Facsimile: (206) 587-4025
*Admitted pro hac vice
Attorneys for Plaintiffs-Petitioners
Attorne1 ·.1jor Plaintiffs-Petitioners
JOINT S'.ll'ULATION AND
...
fORDER
REGM'.l)l'\(I FXCHANGEOF
INITIAL DISCLOSURES AND
SUBMISSION or 26([)
REPORl-::
r'-4nT"'l\l,..
0.10
~•T
()'10
l\rfTTI
Northwest Immigrant Rights Project
615 Second Ave., Ste. 400
Seattle, WA 98104
Telephone (206) 957-8611
Case 2:18-cv-00928-MJP Document 81 Filed 10/15/18 Page 3 of 5
2:18-cv-00928-MJP Document 79 Filed 10/11/18 Page 3 of 5
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JOSEPH. II. HUNT
Assistant Attorney General
Civil Division
WILLIA\1 C. PEACHEY
Director, District Court Section
Office of Jmm i gration Litigation
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EREZ FF U VENI
Assistant ]) irector, District Court Section
Isl Lauren C. Bingham
LAUREN C. BINGHAM, Fl. Bar #105745
Trial Attorney, District Court Section
Office of Immigration Litigation
Civil Division
P.O. Box 868, Ben Franklin Station
Washington, DC 20044
(202) 616-4458; (202) 305-7000 (fax)
lauren.c. bingham@usdoj.gov
Attorneys for Defendants-Respondents
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JOINT STIPULATION AND
II J ORDER
REGARDING EXCHANGE OF
INITIAL DISCLOSURES AND
SUBMISSION OF 26(f)
REPORT- 3
J
Northwest Immigrant Rights Project
615 Second Ave., Ste. 400
Seattle, WA 98104
Telephone (206) 957-8611
Case 2:18-cv-00928-MJP Document 81 Filed 10/15/18 Page 4 of 5
2:18-cv-00928-MJP Document 79 Filed 10/11/18 Page 4 of 5
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ORDER
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D~1scd on the foregoing stipulation of the parties, IT IS SO ORDERED. The parties shall
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exchange initial disclosures by November 5, 2018. The parties shall submit their 26(f) report by
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November 12, 2018.
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DATED this
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JS- day of_~-~--·----' 2018.
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THE HONORABLE ARSHA J. PECHMAN
UNITED STATES STRICT JUDGE
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JOINT STIPULATION AND
JFJWI JORDER
REGARDING EXCHANGE OF
INITIAL DISCLOSURES AND
SUBMISSION OF 26(f)
REPORT- 4
Northwest Immigrant Rights Project
615 Second Ave., Ste. 400
Seattle, WA 98104
Telephone (206) 957-8611
Case 2:18-cv-00928-MJP Document 81 Filed 10/15/18 Page 5 of 5
2:18-cv-00928-MJP Document 79 Filed 10/11/18 Page 5 of 5
CERTIFICATE OF SERVICE
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l licrcby certify that on October 11, 2018, I had the foregoing electronically filed with the
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Clerk of the Court using the CM/ECF system, which will send notification of such filing to those
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attorneys of record registered on the CM/ECF system. All other parties (if any) shall be served
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in accon 1::ncc with the Federal Rules of Civil Procedure.
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Isl Lauren C. Bingham
LAUREN C. BINGHAM, Fl. Bar #105745
Trial Attorney, District Court Section
Office of Immigration Litigation
Civil Division
P.O. Box 868, Ben Franklin Station
Washington, DC 20044
(202) 616-4458; (202) 305-7000 (fax)
lauren.c. bingham@usdoj.gov
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Attorney for Defendants
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JOINT STIPULATION AND
~ORDER
REGARDING EXCHANGE OF
INITIAL DISCLOSURES AND
SUBMISSION OF 26(f)
REPORT- S
Northwest Immigrant Rights Project
61 S Second Ave., Ste. 400
Seattle, WA 98104
Telephone (206) 957-8611
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