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

Filing 127

STIPULATION AND ORDER to Extend Deadline-Related Motions re parties' 126 Stipulated Motion, signed by Judge Robert S. Lasnik. (SWT)

Case 2:18-cv-01115-RSL Document 127 Filed 11/07/18 Page 1 of 4

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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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NO. 2:18-cv-01115-RSL

STATE OF WASHINGTON, et al.,

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STIPULATION TO EXTEND
DEADLINE TO FILE DISCOVERYRELATED MOTIONS

Plaintiffs,
v.

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UNITED STATES DEPARTMENT OF
STATE, et al.,

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NOTING DATE: NOVEMBER 6, 2018

Defendants.

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Pursuant to Local Rules 7(d)(1) and 10(g), the Plaintiff States and the Private Defendants1

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hereby file this stipulated request to extend the deadline to file motions related to discovery

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disputes until 21 days after the Court rules on the Private Defendants’ pending Motion for

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Judgment on the Pleadings. The grounds for this stipulation are as follows:

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1.

The current deadline to file motions related to discovery disputes is November

15, 2018. Dkt. # 115 (Case Management Order), p. 2.
2.

On September 20, 2018, the Plaintiff States propounded a set of discovery

requests on the Private Defendants.
3.

On October 11, 2018, the Private Defendants filed a Motion for Judgment on the

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The Private Defendants are Defense Distributed, the Second Amendment Foundation, and Conn
Williamson. The Federal Defendants do not oppose the relief requested in this stipulation.
STIP. TO EXTEND DEADLINE TO FILE
DISCOVERY-RELATED MOTIONS
2:18-cv-01115-RSL

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Case 2:18-cv-01115-RSL Document 127 Filed 11/07/18 Page 2 of 4

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Pleadings, seeking an order “dismissing them from this action.” Dkt. # 114. As of the filing of

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this stipulation, the motion has been fully briefed but has not been ruled upon.

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4.

On October 22, 2018, the Private Defendants responded to the Plaintiff States’

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discovery requests, objecting on the grounds inter alia that their Motion for Judgment on the

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Pleadings was pending, and that they would not be subject to party discovery if the motion were

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granted.

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5.

The Plaintiff States and the Private Defendants agree that, if the Motion for

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Judgment on the Pleadings were to be granted in full, the Private Defendants would not be subject

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to party discovery. They further agree that postponing their efforts to resolve any discovery

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disputes until after the Court has ruled on the motion will conserve the parties’ resources and

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avoid any need to seek provisional relief in keeping with the current deadline without the benefit

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of a ruling on the motion.

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Based on the above, the Plaintiff States and the Private Defendants jointly request that

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the Court extend the deadline to file discovery-related motions to 21 days after the Court issues

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a ruling on the Motion for Judgment on the Pleadings.

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DATED this 6th day of November, 2018.

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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
ZACH JONES, WSBA #44557
Assistant Attorney General

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STIP. TO EXTEND DEADLINE TO FILE
DISCOVERY-RELATED MOTIONS
2:18-cv-01115-RSL

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Case 2:18-cv-01115-RSL Document 127 Filed 11/07/18 Page 3 of 4

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[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Counsel for the Plaintiff States

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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]
Counsel for the Private Defendants

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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
Counsel for the Private Defendants

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BECK REDDEN LLP
/s/ Charles Flores
Charles Flores*
Beck Redden LLP
1221 McKinney Street, Suite 4500
Houston, TX 77010
Phone: [phone]
[e-mail]
*Admitted pro hac vice
Counsel for Defendant Defense Distributed

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STIP. TO EXTEND DEADLINE TO FILE
DISCOVERY-RELATED MOTIONS
2:18-cv-01115-RSL

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Case 2:18-cv-01115-RSL Document 127 Filed 11/07/18 Page 4 of 4

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

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A

Dated: November 7, 2018

Honorable Robert S. Lasnik
United States District Judge

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STIP. TO EXTEND DEADLINE TO FILE
DISCOVERY-RELATED MOTIONS
2:18-cv-01115-RSL

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