Moen-Lewis v. CDC Management Services, LLC

Filing 12

STIPULATION AND ORDER Continuing Deadline for Motions Related to Discovery Re: Privilege Log and Email Communications of Parker, signed by Judge Robert J. Bryan. (DK)

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The Honorable Robert J. Bryan

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT TACOMA

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JACQUELINE MOEN-LEWIS,
NO. 3:11-cv-05413

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Plaintiff,
STIPULATION AND ORDER CONTINUING
DEADLINE FOR MOTIONS RELATED TO
DISCOVERY RE: PRIVILEGE LOG AND
EMAIL COMMUNICATIONS OF PARKER

and
CDC MANAGEMENT SERVICES, LLC.
and PAUL BOVA, single man,

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Defendants.
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Come now the parties hereto and Stipulate to extend the deadline for motions relating to

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discovery which is currently set for December 19, 2011 to January 30, 2012, PROVIDED THAT

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the extension is strictly limited to motions relating to the Privilege Log currently being prepared

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by the defendants and to the email communications of Deborah Parker which have not yet been

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produced in readable format in response to plaintiff’s most recent discovery requests. The

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reason for the extension is that the case involves thousands of email communications, over 800

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of which have been identified as subject to a claim of work product or of attorney client

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privilege. The defendants are currently revising the Privilege Log to provide sufficient

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information on the Log so that the opposing party can accurately determine whether a privilege
STIP & ORD RE: DISCOVERY

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820 “A” Street, Suite 600
P.O. Box 1533
Tacoma, Washington 98401
[phone]
Fax: [phone]

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or other objection is properly taken. Given the volume of the information, the defendant has

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been unable to complete the Privilege Log and produce it to Plaintiff’s Counsel in a way that it

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can be meaningfully reviewed, considered and evaluated prior to the deadline for discovery

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motions set for next Monday, December 19th. Defendant will complete the Log and deliver it to

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the plaintiff no later than December 30, 2011 so that motions relating to this Privilege Log (and

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emails not yet produced for Deborah Parker) can be timely made by the new proposed deadline

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of January 30, 2011.

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Dated this 15th day of December, 2011

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MORTON MCGOLDRICK, P.S.

GORDON EDMUNDS GRELISH, PLLC

/s/ Kathleen E. Pierce
Kathleen E. Pierce, WSBA No. 12631
Attorney for Plaintiff
820 “A” Street, Suite 600
Tacoma, WA 98402
[phone]
[e-mail]

/s/ Randolph I. Gordon
Randolph I. Gordon WSBA No. 8435
Attorneys for Defendant
1218 3rd Ave. Ste. 1000
Seattle, WA 98101-3290
[phone]
[e-mail]

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***************************************************

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ORDER
This matter having come on for hearing upon the Stipulation of the parties and the Court

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having reviewed the Stipulation and the records and files herein and being fully advised in the

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premises it is hereby

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ORDERED, ADJUDGED AND DECREED the deadline for motions relating to
discovery which is currently set for December 19, 2011 be and hereby is CONTINUED to

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STIP & ORD RE: DISCOVERY

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820 “A” Street, Suite 600
P.O. Box 1533
Tacoma, Washington 98401
[phone]
Fax: [phone]

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January 30, 2012, PROVIDED THAT the extension is strictly limited to motions relating to the

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Privilege Log currently being prepared by the defendants and to the email communications of

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Deborah Parker which have not yet been produced in readable format in response to plaintiff’s

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most recent discovery requests.

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DATED this 15th day of December, 2011.

A

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ROBERT J. BRYAN
United States District Judge

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MORTON MCGOLDRICK, P.S.

GORDON EDMUNDS GRELISH, PLLC

/s/ Kathleen E. Pierce
Kathleen E. Pierce, WSBA No. 12631
Attorney for Plaintiff
820 “A” Street, Suite 600
Tacoma, WA 98402
[phone]
[e-mail]

/s/ Randolph I. Gordon
Randolph I. Gordon WSBA No. 8435
Attorneys for Defendant
1218 3rd Ave. Ste. 1000
Seattle, WA 98101-3290
[phone]
[e-mail]

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STIP & ORD RE: DISCOVERY

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820 “A” Street, Suite 600
P.O. Box 1533
Tacoma, Washington 98401
[phone]
Fax: [phone]