State of Washington et al v. United States Department of State et al

Filing 108

STIPULATION AND ORDER to Extend Deadlines re parties' 105 Stipulation: Federal Defendants may file their Answer on or before 10/9/2018, and may file an administrative record on or before 10/19/2018. Signed by Judge Robert S. Lasnik. (SWT)

Case 2:18-cv-01115-RSL Document 108 Filed 09/28/18 Page 1 of 5

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The Honorable Robert S. Lasnik

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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STATE OF WASHINGTON, et al.,

No. 2:18-cv-01115-RSL

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Plaintiffs,
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v.
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UNITED STATES DEPARTMENT OF
STATE, et al.,

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STIPULATION TO EXTEND
DEADLINE FOR FEDERAL
DEFENDANTS TO RESPOND TO
PLAINITFFS’ AMENDED COMPLAINT
AND FILE AN ADMINISTRATIVE
RECORD

Defendants.
NOTED FOR: SEPTEMBER 27, 2018

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Pursuant to Local Civil Rules 7(d)(1) and 10(g), the parties hereby file this stipulated
request to extend the deadline for the Federal Defendants to respond to Plaintiffs’ Amended
Complaint until and including October 9, 2018, and to extend the deadline for the Federal
Defendants to file an administrative record until and including October 19, 2018. The grounds
for this stipulation are as follows:
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Plaintiffs filed their Complaint in this case on July 30, 2018. ECF No. 1.

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Also on July 30, 2018, Plaintiffs served the Complaint on the U.S. Attorney’s Office for the

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Western District of Washington. Plaintiffs filed an Amended Complaint on August 2, 2018.

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ECF No. 29.
STIP. TO EXTEND DEADLINE TO
RESP. TO AM. COMPL. AND FILE A.R.
2:18-cv-01115-RSL

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Case 2:18-cv-01115-RSL Document 108 Filed 09/28/18 Page 2 of 5

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2.

Pursuant to Federal Rules of Civil Procedure 12(a)(2) and 15(a)(3), the

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Federal Defendants’ response to Plaintiffs’ Amended Complaint is due on or before

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September 28, 2018.

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3.

Pursuant to Local Civil Rule 79(h), the Federal Defendants must file an

administrative record “with the answer or return.”
4.

On September 14, 2018, the parties conferred telephonically pursuant to

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Federal Rule of Civil Procedure 26(f) and Local Civil Rule 16. During that conference, the

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parties discussed suggestions for the prompt and efficient resolution of the case. Since

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September 14, 2018, the parties have continued to negotiate a series of deadlines related to

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the case.
5.

Although the parties have not reached a final agreement regarding all

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deadlines, they have agreed that the Federal Defendants may file their Answer on or before

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October 9, 2018, and that they may file an administrative record on or before October 19,

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2018. While the parties continue to negotiate other deadlines, and in light of the upcoming

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deadline for the Federal Defendants to respond to Plaintiffs’ Amended Complaint, the parties

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accordingly request that the Court extend the deadlines imposed by Federal Rules of Civil

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Procedure 12(a)(2) and 15(a)(3) and Local Civil Rule 79(h), such that the Federal Defendants

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may file their Answer on or before October 9, 2018, and may file an administrative record on

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or before October 19, 2018.

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Dated: September 27, 2018

Respectfully submitted,

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JOSEPH H. HUNT
Assistant Attorney General

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ANNETTE L. HAYES
Acting United States Attorney

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KERRY KEEFE
Civil Chief

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STIP. TO EXTEND DEADLINE TO
RESP. TO AM. COMPL. AND FILE A.R.
2:18-cv-01115-RSL

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Case 2:18-cv-01115-RSL Document 108 Filed 09/28/18 Page 3 of 5

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JOHN R. GRIFFITHS
Director, Federal Programs Branch

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ANTHONY J. COPPOLINO
Deputy Director, Federal Programs Branch

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/s/ Stuart J. Robinson
STUART J. ROBINSON
STEVEN A. MYERS
ERIC J. SOSKIN
Attorneys
U.S. Department of Justice
Civil Division, Federal Programs Branch
450 Golden Gate Ave., Suite 7-5395
San Francisco, CA 94549
415-436-6635 (telephone)
415-436-6632 (facsimile)
[e-mail]

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Counsel for the Federal Defendants

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IMMIX LAW GROUP PC
/s/Joel B. Ard
Joel B. Ard, WSBA # 40104
Immix Law Group PC
701 5th Ave Suite 4710
Seattle, WA 98104
Phone: [phone]
Fax: [phone]
[e-mail]

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Counsel for Defendants Defense Distributed,
Second Amendment Foundation, Inc., and Conn
Williamson

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FARHANG & MEDCOFF
/s/Matthew Goldstein
Matthew Goldstein*
Farhang & Medcoff
4801 E. Broadway Blvd., Suite 311
Tucson, AZ 85711
Phone: [phone]
[e-mail]
*Admitted Pro Hac Vice

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Counsel for Defendants Defense Distributed,
Second Amendment Foundation, Inc., and Conn
Williamson

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BECK REDDEN LLP
/s/Charles Flores
Charles Flores*
[e-mail]

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STIP. TO EXTEND DEADLINE TO
RESP. TO AM. COMPL. AND FILE A.R.
2:18-cv-01115-RSL

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Case 2:18-cv-01115-RSL Document 108 Filed 09/28/18 Page 4 of 5

Beck Redden LLP
1221 McKinney Street, Suite 4500
Phone: [phone]
*Admitted Pro Hac Vice

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Counsel for Defendant Defense Distributed

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ROBERT W. FERGUSON
Attorney General

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/s/ Jeffrey Rupert
JEFFREY RUPERT, WSBA #45037
Division Chief
KRISTIN BENESKI, WSBA #45478
Assistant Attorney General
TODD BOWERS, WSBA #25274
Deputy Attorney General
JEFF SPRUNG, WSBA #23607
Assistant Attorney General
ZACHARY P. JONES, WSBA #44557
Assistant Attorney General
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

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Counsel for the Plaintiff States

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STIP. TO EXTEND DEADLINE TO
RESP. TO AM. COMPL. AND FILE A.R.
2:18-cv-01115-RSL

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Case 2:18-cv-01115-RSL Document 108 Filed 09/28/18 Page 5 of 5

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ORDER APPROVING STIPULATION
PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: September 28, 2018.

A

Honorable Robert S. Lasnik
United States District Judge

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STIP. TO EXTEND DEADLINE TO
RESP. TO AM. COMPL. AND FILE A.R.
2:18-cv-01115-RSL

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