Wright v. State of Washington et al

Filing 32

ORDER granting Parties' 31 Stipulated MOTION to Extend Case Schedule Deadlines. Jury Trial is set for 6/16/2025 before Judge Barbara J. Rothstein. Discovery Motions due by 11/26/2024, Discovery completed by 12/20/2024, Dispositive motions due by 1/21/2025, Motions in Limine due by 5/7/2025, Joint Pretrial Statement due by 5/19/2025, Pretrial Conference set for 6/3/2025 at 10:30 AM. Signed by Hon. S. Kate Vaughan. (SB)

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HONORABLE BARBARA J. ROTHSTEIN
HONORABLE S. KATE VAUGHAN

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

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MATT WRIGHT,
Plaintiff,

v.

STATE OF WASHINGTON, WASHINGTON
STATE DEPARTMENT OF CORRECTIONS,
CHRISTINE GOMES, TRACI DRAKE, DAVID
CHRISTENSEN, CAROL SMITH, LOUISE
STEMLER, JASON MARTIN, JASON RICHER,
ALEX COSTA, RISA KLEMME, NIKKI RYMER,
and DOES I-X inclusive,

I.

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AGREED STIPULATION AND
(PROPOSED) ORDER
EXTENDING CASE SCHEDULE
DEADLINES
Noted for Consideration:
August 27, 2024

Defendants.

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Case No. C23-1326-BJR-SKV

STIPULATION

For good cause shown and pursuant to the Court’s Order Extending the Case Scheduling
Deadlines, Dkt.10, all parties to this matter stipulate as follows:
1.

The parties have been actively engaged in discovery in this matter, including exchange of

written interrogatories and request for production. The parties intend to engage in depositions of fact
witnesses and parties.
2.

The current expert discovery deadline is September 20, 2024. Due to the breadth of

discovery sought and the need for reviewing and redacting records sought by the parties, the parties will

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AGREED STIPULATION AND (PROPOSED)
ORDER EXTENDING CASE SCHEDULE
DEADLINES
Case No. C23-1326-BJR-SKV – 1

LAW, LYMAN, DANIEL,
KAMERRER & BOGDANOVICH, P.S.
ATTORNEYS AT LAW
2674 R.W. JOHNSON RD. TUMWATER, WA 98512
P.O. BOX 11880 OLYMPIA, WASHINGTON 98508-1880
[phone] FAX: [phone]

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need additional time to complete discovery. The parties anticipate that an additional three (3) months

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from the current deadline will be sufficient. The parties do not anticipate any further extensions of this

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Court’s deadlines.
3.

The parties agree that the purpose of this extension is to allow more time to review,

redact, and produce responsive records sought by the parties. The parties agree that no further written
discovery will be propounded after this Court’s current discovery deadline of September 20, 2024.
3.

Extending the discovery deadline will make it difficult to maintain the remaining dates on

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the case schedule order, including expert related motions and dispositive motions, as well the ability to

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evaluate the case for potential pretrial mediation. Therefore, the parties request that all remaining dates

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on the case schedule also be extended as follows:
EVENT

CURRENT DEADLINE

NEW DEADLINE

Discovery Motions

August 26, 2024

November 26, 2024

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Discovery Deadline

September 20, 2024

December 20, 2025

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Dispositive Motions

October 21, 2024

January 21, 2025

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Motions in Limine

February 12, 2025

May 12, 2025

Joint Pretrial Statement

February 19, 2025

May 19, 2025

Jury Trial

March 17, 2025

June 17, 2025

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STIPULATED TO THIS 27th DAY OF August 2024.

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LAW, LYMAN, DANIEL, KAMERRER
& BOGDANOVICH, P.S.

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/s/ John E. Justice

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John E. Justice, WSBA No. 23042
Attorney for Defendants
P.O. Box 11880, Olympia, WA 98508

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AGREED STIPULATION AND (PROPOSED)
ORDER EXTENDING CASE SCHEDULE
DEADLINES
Case No. C23-1326-BJR-SKV – 2

LAW, LYMAN, DANIEL,
KAMERRER & BOGDANOVICH, P.S.
ATTORNEYS AT LAW
2674 R.W. JOHNSON RD. TUMWATER, WA 98512
P.O. BOX 11880 OLYMPIA, WASHINGTON 98508-1880
[phone] FAX: [phone]

Phone: [phone] Fax: [phone]
[e-mail]
/s/ Darryl Parker
Darryl Parker, WSBA No. 30770
Attorney for Plaintiff
CIVIL RIGHTS JUSTICE CENTER PLLC
1833 N 105th Street, Suite 201
Seattle, WA 98133
[e-mail]

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ORDER

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Pursuant to the stipulation of the parties, and for good cause shown, the Case Schedule Order is
modified as follows:
EVENT

CURRENT DEADLINE

NEW DEADLINE

Discovery Motions

August 26, 2024

November 26, 2024

Discovery Deadline

September 20, 2024

December 20, 2024

Dispositive Motions

October 21, 2024

January 21, 2025

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Motions in Limine

February 12, 2025

May 7, 2025

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Joint Pretrial Statement

February 19, 2025

May 19, 2025

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Pretrial Conference

March 4, 2025 at 10:30 am

June 3, 2025 at 10:30 am

Jury Trial

March 17, 2025

June 16, 2025

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DONE THIS 28th DAY OF August, 2024

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S. KATE VAUGHAN
United States Magistrate Judge

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AGREED STIPULATION AND (PROPOSED)
ORDER EXTENDING CASE SCHEDULE
DEADLINES
Case No. C23-1326-BJR-SKV – 3

LAW, LYMAN, DANIEL,
KAMERRER & BOGDANOVICH, P.S.
ATTORNEYS AT LAW
2674 R.W. JOHNSON RD. TUMWATER, WA 98512
P.O. BOX 11880 OLYMPIA, WASHINGTON 98508-1880
[phone] FAX: [phone]

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CERTIFICATE OF FILING AND SERVICE
I hereby certify under penalty of perjury under the laws of the United States of America that on
this date, I caused to be electronically filed the foregoing document, and this Certificate of Filing & Service
with the CM/ECF e-filing portal which will cause the same to be served on the following:
Plaintiffs Attorney:
Darryl Parker
CIVIL RIGHTS JUSTICE CENTER PLLC
1833 N 105th Street, Suite 201
Seattle, WA 98133
[e-mail]
DATED this 27th day of August, 2024 at Tumwater, WA.

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/s/ Lisa Gates
______________________
Lisa Gates, Legal Assistant

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AGREED STIPULATION AND (PROPOSED)
ORDER EXTENDING CASE SCHEDULE
DEADLINES
Case No. C23-1326-BJR-SKV – 4

LAW, LYMAN, DANIEL,
KAMERRER & BOGDANOVICH, P.S.
ATTORNEYS AT LAW
2674 R.W. JOHNSON RD. TUMWATER, WA 98512
P.O. BOX 11880 OLYMPIA, WASHINGTON 98508-1880
[phone] FAX: [phone]