Killam v. Port of Seattle

Filing 11

ORDER re parties' 10 Stipulated Motion for Stay of Case Until 7/6/2020 Pending Settlement Negotiations. Defendant's deadline to file a responsive pleading is extended to July 6, 2020. Joint Status Report due by 7/2/2020. Signed by Judge Ricardo S. Martinez.(PM)

Case 2:20-cv-00432-RSM Document 11 Filed 06/03/20 Page 1 of 4

1

THE HONORABLE RICARDO S. MARTINEZ

2
3
4
5
6
7
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

8
9
10
11
12
13

Adrianna Killam,
Plaintiff,
v.
Port of Seattle,

Case No.: 2:20-cv-00432-RSM
STIPULATION AND ORDER FOR
STAY OF CASE UNTIL JULY 6, 2020
PENDING SETTLEMENT
NEGOTIATIONS

Defendant.
NOTED FOR CONSIDERATION:
June 3, 2020

14
15
16
17

I. STIPULATION
Plaintiff Adrianna Killam filed her Complaint on March 20, 2020 (Dkt. # 1). On May 8,

18

2020, the Court ordered a stay of all deadlines in this case until June 5, 2020 (Dkt. #6). The

19

Parties have participated in settlement discussions and agree that an additional stay of this case

20

until July 6, 2020 is appropriate.

21

This additional extension of time will permit the Parties to continue to engage in

22

settlement discussions that have already commenced and potentially resolve this matter without

23

further action by the Court. The Parties believe that these settlement efforts will be compromised

24
STIPULATION AND ORDER FOR STAY OF CASE UNTIL JULY 6, 2020
PENDING SETTLEMENT NEGOTIATIONS - 1
2:20-cv-00432-RSM

STOKES LAWRENCE, P.S.
1420 FIFTH AVENUE, SUITE 3000
SEATTLE, WASHINGTON 98101-2393
[phone]

Case 2:20-cv-00432-RSM Document 11 Filed 06/03/20 Page 2 of 4

1

by simultaneous prelitigation civil filings and practice and that there is good cause for the stay

2

requested. Representative counsel for the parties agreed to extending the stay during a telephone

3

conference and related e-mail correspondence on Monday, June 1, 2020.

4

Thus, the Parties respectfully request the Court to enter an Order:

5

i.

on and conduct settlement negotiations; and

6
7

Staying this action for all purposes until July 6, 2020, so that the Parties can focus

ii.

Scheduling a status hearing date for the Parties to file a joint report, or other event

8

that will permit the Parties to update the Court on the progress of settlement

9

efforts following the conclusion of the stay on July 6, 2020.

10
11

EXECUTED at Seattle, WA, this 3rd day of June, 2020.

12
STOKES LAWRENCE, P.S.

WASHINGTON CIVIL AND DISABILITY
ADVOCATE

By: /s/ Justo G. Gonzalez
Justo G. Gonzalez (WSBA #39127)

By: /s/ Conrad Reynoldson
Conrad Reynoldson (WSBA #48187)

By: /s/ Joshua D. Harms
Joshua D. Harms (WSBA #55679)

By: /s/ Jill Sulzberg
Jill Sulzberg (WSBA # 55946)

21

Stokes Lawrence, P.S.
1420 Fifth Avenue, Suite 3000
Seattle, WA 98101-2393
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
E-mail: [e-mail]

Washington Civil and Disability Advocate
4115 Roosevelt Way NE, Ste B
Seattle, WA 98105
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
E-mail: [e-mail]

22

Attorneys for Defendant Port of Seattle

Attorneys for Plaintiff Adrianna Killiam

13
14
15
16
17
18
19
20

23
24
STIPULATION AND ORDER FOR STAY OF CASE UNTIL JULY 6, 2020
PENDING SETTLEMENT NEGOTIATIONS - 2
2:20-cv-00432-RSM

STOKES LAWRENCE, P.S.
1420 FIFTH AVENUE, SUITE 3000
SEATTLE, WASHINGTON 98101-2393
[phone]

Case 2:20-cv-00432-RSM Document 11 Filed 06/03/20 Page 3 of 4

ORDER

1
2

Based on the foregoing Stipulation and Motion, IT IS SO ORDERED that Defendant’s

3

deadline to file a responsive pleading is extended to July 6, 2020. The parties are directed to file

4

a joint status report no later than July 2, 2020, indicating:

5

1) Whether the stay should be lifted or extended;  

6

2) The agreed date upon which Defendant’s responsive pleading is due; and

7

3) Proposed dates for the Court to reset deadlines for the FRCP 26(f) conference, initial

8
9

disclosures, and a combined joint status report and discovery plan.
DATED this 3rd day of June, 2020.

10
11

A

12

RICARDO S. MARTINEZ
CHIEF UNITED STATES DISTRICT JUDGE

13
14
15
16
17
Presented by:
18
19

STOKES LAWRENCE, P.S.

20

By: /s/ Justo G. Gonzalez
Justo G. Gonzalez (WSBA #39127)

21
22
23

By: /s/ Joshua D. Harms
Joshua D. Harms (WSBA #55679)
Attorneys for Defendant Port of Seattle

24
STIPULATION AND ORDER FOR STAY OF CASE UNTIL JULY 6, 2020
PENDING SETTLEMENT NEGOTIATIONS - 3
2:20-cv-00432-RSM

STOKES LAWRENCE, P.S.
1420 FIFTH AVENUE, SUITE 3000
SEATTLE, WASHINGTON 98101-2393
[phone]

Case 2:20-cv-00432-RSM Document 11 Filed 06/03/20 Page 4 of 4

1
2

WASHINGTON CIVIL AND DISABILITY ADVOCATE

3

By: /s/ Conrad Reynoldson
Conrad Reynoldson (WSBA #48187)

4
5
6

By: /s/ Jill Sulzberg
Jill Sulzberg (WSBA # 55946)
Attorneys for Plaintiff Adrianna Killiam

7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
STIPULATION AND ORDER FOR STAY OF CASE UNTIL JULY 6, 2020
PENDING SETTLEMENT NEGOTIATIONS - 4
2:20-cv-00432-RSM

STOKES LAWRENCE, P.S.
1420 FIFTH AVENUE, SUITE 3000
SEATTLE, WASHINGTON 98101-2393
[phone]