Monroy et al v. Real Time Resolutions Inc et al

Filing 62

ORDER granting Parties' 60 Stipulated MOTION and Proposed Order to Extend Trial and Remaining Case Deadlines. Jury Trial (4 days) is set for 5/15/2023 before Judge Barbara J. Rothstein. Discovery to be completed, and Discovery mot ions due, by 10/31/2022, Dispositive motions due by 12/14/2022, Motions in Limine due by 4/7/2023, Joint Pretrial Statement due by 4/14/2023, Pretrial Conference set for 5/3/2023 before Judge Barbara J. Rothstein. Signed by Judge Barbara J. Rothstein.(MW)

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Case 2:21-cv-00813-BJR Document 62 Filed 08/02/22 Page 1 of 5 1 2 3 4 5 6 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 7 8 9 ALBERTO RIVERA MONROY and IRMA PARRA-RIVERA, husband and wife, Plaintiffs, 10 11 12 13 v. REAL TIME RESOLUTIONS INC., MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., and MTC FINANCIAL INC. d/b/a TRUSTEE CORPS. 14 2:21-cv-00813-BJR STIPULATED MOTION AND ORDER TO EXTEND TRIAL AND REMAINING CASE DEADLINES Defendants. 15 16 REAL TIME RESOLUTIONS INC., Counterclaim-Plaintiff, 17 18 v. 19 ALBERTO RIVERA MONROY and IRMA PARRA-RIVERA, husband and wife, 20 Counterclaim-Defendants. 21 22 I. 23 24 25 26 STIPULATED MOTION The Plaintiffs, Alberto Rivera Monroy and Irma Parra-Rivera, husband and wife and the marital community composed thereof, collectively (“Plaintiffs / Counterclaim Defendants”), and Real Time Resolutions, Inc. (“RTR”), Mortgage Electronic Registration Systems, Inc. STIPULATED MOTION AND TO EXTEND TRIAL AND CASE DEADLINES - 1 2:21-cv-00813-BJR HENRY & DEGRAAFF, P.S. 113 CHERRY ST, PMB 58364 SEATTLE, WA 98104 V (206) 330-0595 / F (206) 400-7609 Case 2:21-cv-00813-BJR Document 62 Filed 08/02/22 Page 2 of 5 1 (“MERS”), and MTC Financial Inc., d/b/a Trustee Corps (“MTC”), by and through their 2 undersigned counsel, stipulate as follows: 3 Plaintiffs intend to take the oral, remote deposition of RTR's 30(b)(6) deponent and 4 MERS’ 30(b)(6) deponent, and RTR intends to take the oral, remote deposition of Plaintiffs. 5 The parties have met and agreed to extend the trial and case schedule deadlines as set forth 6 herein pursuant to Local Rules (d)(1), 10(g) and 16(b) and hereby file this stipulated motion to 7 request that the court continue the deadlines as set forth herein in the case schedule and for a 8 continuation of the Trial as currently set by the Court’s Order Setting Jury Trial and Pretrial 9 Dates (Dkt No. 46). 10 This is the second request for an extension of the case schedule requested by the parties. 11 At this stage in the litigation, the parties are working together in good faith to complete 12 discovery and other matters in the case and believe that there is good cause for an extension of 13 deadlines as requested herein. 14 Specifically, the parties are in the process of narrowing certain outstanding discovery 15 disputes relating to discovery requests which have already been propounded and responded to, 16 which they expect to be completed by August 10, 2022, and after that date, the parties intend to 17 bring any remaining outstanding issues before the court for resolution via a telephone 18 conference and/or discovery motions for resolution. Once these disputes are resolved, the 19 parties will set dates to depose the Rule 30(b)(6) witnesses for RTR, MERS, and Plaintiffs on 20 deposition notices that have already been served. Thus, the continuance of the trial and the 21 below deadlines will allow resolution of the remaining discovery issues in this case and thus 22 the Parties request a 90 (day) extension as detailed herein, with the trial extended out 23 accordingly. For the avoidance of doubt, the Parties do not intend and do not agree that the 24 requested extension will permit any new written discovery requests or notices of deposition. 25 Rather, the Parties intend and agree to allow sufficient time to resolve disputes on those existing 26 discovery requests that have already been propounded, and completion of those depositions that have already been noticed. The Parties agree they do not waive any rights via this stipulation. STIPULATED MOTION AND TO EXTEND TRIAL AND CASE DEADLINES - 2 2:21-cv-00813-BJR HENRY & DEGRAAFF, P.S. 113 CHERRY ST, PMB 58364 SEATTLE, WA 98104 V (206) 330-0595 / F (206) 400-7609 Case 2:21-cv-00813-BJR Document 62 Filed 08/02/22 Page 3 of 5 1 Trial Date 2 Current Date New Date 2/13/2023 5/13/2023 3 or a date convenient for the Court 4 Completion of Outstanding 5 Depositions and discovery 6 motions regarding Pending 7 Discovery1 8 All dispositive Motion must 9 be Completed by 7/31/2022 10/31/2022 9/14/2022 12/14/2022 1/7/2023 4/7/2023 10 All motions in limine must 11 be filed by 12 Joint Pretrial Statement 1/14/2023 4/14/2023 Pretrial Conference 1/30/2023 4/30/2023 Length of Trial 4 days Jury 13 14 15 16 17 18 STIPULATED this 28th day of July, 2022 19 20 21 22 23 24 25 26 1 The Parties agree that no new written discovery or deposition notices are included in this request, and none will be allowed under this stipulation. “Outstanding Discovery” and “Pending Discovery,” as used in this stipulation and order refer only to the depositions of plaintiffs, to the 30(b)(6) depositions of RTR and MERS, and to the written discovery requests and responses that have already been propounded in this case. STIPULATED MOTION AND TO EXTEND TRIAL AND CASE DEADLINES - 3 2:21-cv-00813-BJR HENRY & DEGRAAFF, P.S. 113 CHERRY ST, PMB 58364 SEATTLE, WA 98104 V (206) 330-0595 / F (206) 400-7609 Case 2:21-cv-00813-BJR Document 62 Filed 08/02/22 Page 4 of 5 1 2 3 4 5 6 7 BARRAZA LAW, PLLC HENRY & DEGRAAFF, PS _/s/ V. Omar Barraza_______ V. Omar Barraza, WSBA #43589 10728 16th Avenue SW Seattle, Washington 98146 omar@barrazalaw.com Tel.: (206) 933-7861 Fax.: (206) 933-7863 /s/ Christina L Henry Christina L Henry, WSBA #31273 113 Cherry St, PMB 58364 Seattle, Washington 98104 chenry@hdm-legal.com Tel.: (206) 330-0595 Fax.: +1 (206) 400-7609 8 9 10 11 12 13 14 15 16 PETERSON RUSSELL KELLY, PLLC HOLLAND & KNIGHT, LLP _/s/ Michael Steven DeLeo___ Michael Steven DeLeo, WSBA 22037 Counsel for Defendant MTC Financial, Inc., dba Trustee Corps 1850 Skyline Tower 10900 NE 4th St Bellevue, WA 98004-8341 425-462-4700 Fax 452-451-0714 mdeleo@prklaw.com __/s/ Garrett S. Garfield_________ Garrett S. Garfield, WSBA# 458375 601 Southwest 2nd Ave #1800 Portland, Oregon 97204 Garrett.Garfield@hklaw.com John.Joseph@hklaw.com 17 18 19 20 21 22 23 24 25 26 STIPULATED MOTION AND TO EXTEND TRIAL AND CASE DEADLINES - 4 2:21-cv-00813-BJR HENRY & DEGRAAFF, P.S. 113 CHERRY ST, PMB 58364 SEATTLE, WA 98104 V (206) 330-0595 / F (206) 400-7609 Case 2:21-cv-00813-BJR Document 62 Filed 08/02/22 Page 5 of 5 II. ORDER 1 2 3 The Court having considered the foregoing stipulated motion of the Parties in this case, and finding that good cause has been shown for the requested relief, now therefore, 4 5 6 it is hereby ORDERED as follows: 7 8 Trial Date 2/13/2023 New Date 5/15/2023 or a date convenient for the Court 7/31/2022 10/31/2022 9/14/2022/ 12/14/2022 1/7/2023 4/7/2023 Joint Pretrial Statement 1/14/2023 4/14/2023 Pretrial Conference 1/30/2023 5/3/2023 Length of Trial 4 days Jury 9 10 11 12 13 14 15 16 17 18 19 20 Completion of Outstanding Current Date Depositions and discovery motions regarding Pending Discovery All dispositive Motion must be Completed by All motions in limine must be filed by 21 22 DONE THIS 2nd day of August, 2022. 23 24 25 The Hon. Barbara J. Rothstein United States District Court Judge 26 STIPULATED MOTION AND TO EXTEND TRIAL AND CASE DEADLINES - 5 2:21-cv-00813-BJR HENRY & DEGRAAFF, P.S. 113 CHERRY ST, PMB 58364 SEATTLE, WA 98104 V (206) 330-0595 / F (206) 400-7609

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