Killam v. Port of Seattle

Filing 6

ORDER re parties' 5 Stipulated Motion for Stay of Case Until June 5 Pending Settlement Negotiations. Case stayed until 6/5/2020; Joint Status Report due by 6/4/2020. Signed by Judge Ricardo S. Martinez.(PM)

Case 2:20-cv-00432-RSM Document 6 Filed 05/08/20 Page 1 of 4

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THE HONORABLE RICHARD S. MARTINEZ

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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Adrianna Killam,
Plaintiff,
v.
Port of Seattle,

Case No.: 2:20-cv-00432-RSM
STIPULATION AND ORDER FOR
STAY OF CASE UNTIL JUNE 5
PENDING SETTLEMENT
NEGOTIATIONS

Defendant.
NOTED FOR CONSIDERATION:
May 7, 2020

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I. STIPULATION
Plaintiff Adrianna Killam filed her Complaint for Declaratory and Injunctive Demand on

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March 20, 2020 (Dkt. # 1). In order to provide the Parties with additional time to fully explore

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early settlement resolution, the parties, by and through their respective counsel of record, hereby

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stipulate and move for an order temporarily staying litigation on this case until June 5, 2020.

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This brief extension of time will permit the parties to engage in settlement discussions

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that have already commenced and potentially resolve this matter without further action by the

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Court. The Parties believe that these settlement efforts will be compromised by simultaneous

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STIPULATION AND ORDER FOR STAY OF CASE UNTIL JUNE 5 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 6 Filed 05/08/20 Page 2 of 4

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prelitigation civil filings and practice and that there is good cause for the stay requested.

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Representative counsel for the parties agreed to an extension during a telephone discussion on

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Wednesday, May 6th, 2020.

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Thus, the Parties respectfully request the Court to enter an Order:
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on and conduct settlement negotiations; and

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Staying this action for all purposes until June 5, 2020, so that the Parties can focus

ii.

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

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

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efforts following the conclusion of the stay on June 5, 2020.

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EXECUTED at Seattle, WA, this 7th day of May 2020.

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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/ Michael M. Terasaki
Michael M. Terasaki (WSBA #51923)

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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]

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Attorneys for Defendant Port of Seattle

Attorneys for Plaintiff Adrianna Killiam

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STIPULATION AND ORDER FOR STAY OF CASE UNTIL JUNE 5 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 6 Filed 05/08/20 Page 3 of 4

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ORDER

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

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to file a responsive pleading is extended to June 5, 2020. The parties are directed to file a joint

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status report no later than June 4, 2020, indicating:

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1) Whether the stay should be lifted or extended;

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

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3) Proposed dates for the Court to reset deadlines for the FRCP 26(f) conference, initial
disclosures, and a combined joint status report and discovery plan.

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DATED this 8th day of May, 2020.

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A

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RICARDO S. MARTINEZ
CHIEF UNITED STATES DISTRICT JUDGE

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Presented by:
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STOKES LAWRENCE, P.S.

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

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

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STIPULATION AND ORDER FOR STAY OF CASE UNTIL JUNE 5 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 6 Filed 05/08/20 Page 4 of 4

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WASHINGTON CIVIL AND DISABILITY ADVOCATE

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

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By: /s/ Michael M. Terasaki
Michael M. Terasaki (WSBA #51923)
Attorneys for Plaintiff Adrianna Killiam
5/7/2020 - Mr. Reynoldson and Mr. Terasaki
Confirmed E-Signature via E-mail

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STIPULATION AND ORDER FOR STAY OF CASE UNTIL JUNE 5 PENDING
SETTLEMENT NEGOTIATIONS - 4

2:20-cv-00432-RSM

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