Kairu v. United States of America

Filing 15

ORDER granting Parties' 14 Stipulated MOTION for Extension of Pretrial Deadlines. Expert Witness Disclosure/Reports under FRCP 26(a)(2) due by 12/28/2022, Discovery completed by 2/28/2023, Dispositive motions due by 3/28/2023. Signed by Judge Barbara J. Rothstein. (SB)

The Honorable Barbara J. Rothstein

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UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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LUCY W. KAIRU,

Case No. 2:22-cv-00154-BJR
Plaintiff,

v.

THE UNITED STATES OF AMERICA,
Defendant.

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JOINT STIPULATION

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STIPULATED MOTION AND ORDER
FOR EXTENSION OF PRETRIAL
DEADLINES

The parties hereby jointly STIPULATE AND AGREE to extend the following trial date

16 and related dates as set forth in the Court’s June 30, 2022 Order Setting Trial Date and Related
17 Dates (Dkt. 12), as set forth below.
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Deadline

Current Deadline

Proposed New Deadline

Reports from expert witness under
FRCP 26(a)(2) due

November 28, 2022

December 28, 2022

Discovery completed by

December 28, 2022

February 28, 2023

January 27, 2023

March 28, 2023

All dispositive motions must be filed by

Good cause exists for extending these specific deadlines. Although the parties have

24 conducted extensive fact discovery to date, including exchanging written discovery, setting and
STIPULATED MOTION AND [PROPOSED] ORDER FOR
EXTENSION OF PRETRIAL DEADLINES
[2:22-cv-00154-BJR] - 1

UNITED STATES ATTORNEY
700 Stewart Street, Suite 5220
Seattle, Washington 98101-1271
206-553-7970

1 taking depositions, and collecting thousands of pages of medical records, the parties need
2 additional time before expert witnesses can be disclosed. Due to holiday schedules, the timing of
3 when new medical records were received from medical facilities, and the significant volume of
4 records, the parties’ experts need additional time to review records and prepare their expert reports.
5 The parties anticipate that an additional month will be sufficient for their experts to finalize their
6 reports. The parties reasonably anticipate that rebuttal experts will be named and an extension of
7 the close of discovery by two months will allow the parties time to depose any rebuttal experts
8 prior to the close of discovery.
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For the reasons set forth above, the parties believe that there is good cause to request an

10 extension of the above-listed trial date and related dates and respectfully request that the Court
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SO STIPULATED.

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Dated this 15th day of November, 2022.

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NICHOLAS W. BROWN
United States Attorney

CMG LAW

s/ Whitney Passmore
WHITNEY PASSMORE, FL No. 91922

s/ Tyler Goldberg-Hoss
TYLER GOLDBERG-HOSS, WSBA No. 41653
115 NE 100th Street, Ste. 220
Seattle, WA 98125
Phone: [phone]
Email: [e-mail]

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s/ Nickolas Bohl
NICKOLAS BOHL, WSBA No. 48978
Assistant United States Attorneys
United States Attorney’s Office
700 Stewart Street, Suite 5220
Seattle, Washington 98101-1271
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Email: [e-mail]

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Attorneys for United States of America

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Attorney for Plaintiff

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STIPULATED MOTION AND [PROPOSED] ORDER FOR
EXTENSION OF PRETRIAL DEADLINES
[2:22-cv-00154-BJR] - 2

UNITED STATES ATTORNEY
700 Stewart Street, Suite 5220
Seattle, Washington 98101-1271
206-553-7970

ORDER

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It is hereby ORDERED that the parties’ motion is GRANTED. The new pretrial deadlines

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Deadlines
Reports from expert witness under FRCP 26(a)(2) due

December 28, 2022

Discovery completed by

February 28, 2023

All dispositive motions must be filed by

March 28, 2023

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DATED this 18th day of November, 2022.

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A

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Barbara Jacobs Rothstein
U.S. District Court Judge

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STIPULATED MOTION AND [PROPOSED] ORDER FOR
EXTENSION OF PRETRIAL DEADLINES
[2:22-cv-00154-BJR] - 3

UNITED STATES ATTORNEY
700 Stewart Street, Suite 5220
Seattle, Washington 98101-1271
206-553-7970