Hagen v. Safeway Inc

Filing 9

ORDER re Parties' 8 Stipulation for Amending Trial Date and Case Schedule. Jury Trial is CONTINUED to 6/21/2021 at 09:00 AM before Judge Ricardo S. Martinez. Expert Witness Disclosure/Reports under FRCP 26(a) (2) due by 1/8/2021 , Discovery Motions due by 1/28/2021, Discovery completed by 2/26/2021, Dispositive motions due by 3/19/2021, 39.1 mediation to be completed by 4/16/2021, Motions in Limine due by 5/26/2021, Agreed Pretrial Order due by 6/9/2021, Voir dire/jury instructions/trial briefs/exhibits due by 6/16/2021. Signed by Judge Ricardo S. Martinez. (PM)

Case 2:20-cv-00134-RSM Document 9 Filed 10/13/20 Page 1 of 4

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THE HONORABLE RICARDO S. MARTINEZ

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IN THE UNITED STATES DISTRICT COURT

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FOR THE WESTERN DISTRICT OF WASHINGTON

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AT SEATTLE

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TODD HAGEN,
No. 2:20-cv-00134-RSM

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Plaintiff,

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vs.
SAFEWAY, INC., a Delaware Corporation,

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STIPULATION FOR AND
AGREED ORDER AMENDING
TRIAL DATE AND CASE
SCHEDULE

Defendant.

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I. STIPULATION

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The parties stipulate and agree as follows:

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1.

The parties’ joint status report in this matter was filed on March 2, 2020, just

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before the courts began issuing pandemic-related orders and just before the governor

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began issuing stay at home orders.

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2.

The parties have endeavored to continue with discovery but discovery has

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definitely been delayed as a result of the pandemic. The parties need additional time to

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comply with discovery deadlines and to prepare for trial. The deposition of the plaintiff

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is scheduled to take place on October 26, 2020. The parties need additional time for a
STIPULATION FOR AND AGREED
ORDER AMENDING TRIAL DATE
AND CASE SCHEDULE - 1
C:\Users\LowellWilliams\Desktop\Hagen C20-134 order amend
trial date.wpd

Turner Kugler Law,
PLLC
6523 California Ave SW #454
Seattle, WA 98136
[phone]

Case 2:20-cv-00134-RSM Document 9 Filed 10/13/20 Page 2 of 4

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Rule 35 physical examination, to prepare and disclose expert reports and to complete

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other discovery.

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3.

The parties have not previously requested a continuance.

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4.

The parties jointly request that the court enter the subjoined order and

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amend its order setting trial date and related dates (dkt. #7) by setting the following new

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dates:

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Disclosure of expert testimony

January 8, 2021

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Deadline for filing motions related to discovery

January 28, 2021

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Discovery completed by

February 26, 2021

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Dispositive motion filing deadline

March 19, 2021

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Mediation per LCR 39.1(c)(3)

April 16, 2021

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Motion in limine filing deadline

May 26, 2021

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Agreed pretrial order due

June 9, 2021

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Trial briefs, proposed voir dire, jury instructions,
neutral statement of the case, trial exhibits

June 16, 2021

Trial

June 21, 2021

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Dated: October 13, 2020.
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DIXON & CANNON, LTD.
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By:
s/ James R. Dixon
James R. Dixon, WSBA # 18014
Attorney for Plaintiff

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TURNER KUGLER LAW, PLLC

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By:
s/ John T. Kugler
John T. Kugler, WSBA # 19960
Attorney for Defendant

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STIPULATION FOR AND AGREED
ORDER AMENDING TRIAL DATE
AND CASE SCHEDULE - 2
C:\Users\LowellWilliams\Desktop\Hagen C20-134 order amend
trial date.wpd

Turner Kugler Law,
PLLC
6523 California Ave SW #454
Seattle, WA 98136
[phone]

Case 2:20-cv-00134-RSM Document 9 Filed 10/13/20 Page 3 of 4

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II. ORDER
The court has reviewed the foregoing stipulation of the parties and ORDERS that
the original order setting trial date and related dates (dkt. #7) is amended as follows:

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Disclosure of expert testimony

January 8, 2021

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Deadline for filing motions related to discovery

January 28, 2021

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Discovery completed by

February 26, 2021

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Dispositive motion filing deadline

March 19, 2021

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Mediation per LCR 39.1(c)(3)

April 16, 2021

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Motion in limine filing deadline

May 26, 2021

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Agreed pretrial order due

June 9, 2021

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Trial briefs, proposed voir dire, jury instructions,
neutral statement of the case, trial exhibits

June 16, 2021

Trial

June 21, 2021

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DATED: October 13, 2020.
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A

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RICARDO S. MARTINEZ
CHIEF UNITED STATES DISTRICT JUDGE

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STIPULATION FOR AND AGREED
ORDER AMENDING TRIAL DATE
AND CASE SCHEDULE - 3
C:\Users\LowellWilliams\Desktop\Hagen C20-134 order amend
trial date.wpd

Turner Kugler Law,
PLLC
6523 California Ave SW #454
Seattle, WA 98136
[phone]

Case 2:20-cv-00134-RSM Document 9 Filed 10/13/20 Page 4 of 4

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CERTIFICATE OF SERVICE

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I hereby certify that on October 13,
2020, I electronically filed the foregoing with
the Clerk of the Court using the CM/ECF
system which will send notification of such
filing to the following:

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Attorney for Plaintiff:
James Dixon
Dixon & Cannon, Ltd.
601 Union St., Ste. 3230
Seattle, WA 98101
[phone]
[e-mail]

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and I hereby certify that I have mailed by
United States Postal Service the document to
the following non-CM/ECF participants:

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none

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s/ John

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T. Kugler
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JOHN T.
KUGLER, WSB #19960

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Attorney for
Defendant Safeway Inc.

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TURNER
KUGLER LAW, PLLC

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6523
California Ave SW #454

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Seattle,
WA 98136-1833

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Telephone:
[phone]

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E-mail:
[e-mail]

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STIPULATION FOR AND AGREED
ORDER AMENDING TRIAL DATE
AND CASE SCHEDULE - 4
C:\Users\LowellWilliams\Desktop\Hagen C20-134 order amend
trial date.wpd

Turner Kugler Law,
PLLC
6523 California Ave SW #454
Seattle, WA 98136
[phone]