Reed v. Department of Corrections et al

Filing 219

ORDER granting Parties' 218 Stipulated Motion for Limited Reopening of Discovery. Signed by Judge Benjamin H. Settle.(MW)

HONORABLE BENJAMIN H. SETTLE

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT TACOMA

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CHARLES REED,
Plaintiff,

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v.
STEVEN HAMMOND, et al.,

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STIPULATED MOTION AND
AGREED ORDER FOR LIMITED
REOPENING OF DISCOVERY

Defendants.

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No.: 3:16-cv-05993-BHS-DWC

I.

STIPULATED MOTION

The parties stipulate and agree to a limited reopening of discovery for the purpose of
exchanging Plaintiff Charles Reed’s medical records from the Department of Corrections
preceding his release in 2023 that have not already been produced, as well as his medical records
from the Veteran’s Association Hospital where he has been seeking care since his release. All
documents are to be timely exchanged following this Stipulation being granted by the Court. The
parties further stipulate and agree that the documents exchanged may be provided to their
witnesses designated as experts for the purposes of supplementing any expert report, the
supplement of which must be exchanged no later than October 4, 2024. The parties further stipulate
and agree that should this exchange of information and supplemented reports not be reasonably
possible prior to October 4, 2024, that the parties will promptly request the Court for a short trial
continuance.
STIPULATION AND ORDER FOR LIMITED
REOPENING OF DISCOVERY
(NO.: 3:16-CV-05993-BHS-DWC - 1

K&L GATES LLP

925 FOURTH AVENUE, SUITE 2900
SEATTLE, WA 98104-1158
TELEPHONE: [phone]
FACSIMILE: [phone]

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DATED this 6th day of September, 2024
K&L GATES LLP

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By: s/ Monica A. Romero
Monica A. Romero, WSBA No. 58376
Peter A. Talevich, WSBA No. 42644
Tyler K. Lichter, WSBA No. 51090
Emaan R. Jaberi, WSBA No. 56990
[e-mail]
[e-mail]
[e-mail]
[e-mail]

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Attorneys for Plaintiff

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ROBERT W. FERGUSON
Office of the Attorney General for the State of
Washington
By: s/ Scott M. Barbara
Scott M. Barbara, WSBA No. 20885
Aaron Williams, WSBA No. 46044
Assistant Attorneys General
[e-mail]
[e-mail]

Attorneys for Defendants

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STIPULATION AND ORDER FOR LIMITED
REOPENING OF DISCOVERY
(NO.: 3:16-CV-05993-BHS-DWC - 2

K&L GATES LLP

925 FOURTH AVENUE, SUITE 2900
SEATTLE, WA 98104-1158
TELEPHONE: [phone]
FACSIMILE: [phone]

II.

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ORDER

Pursuant to the Parties’ stipulation, it is so ordered.
DATED this 6th day of September, 2024.

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BENJAMIN H. SETTLE
United States District Judge

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STIPULATED AND PRESENTED this 6th day of September, 2024, by:

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K&L GATES LLP

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By: s/ Monica A. Romero
Monica A. Romero, WSBA No. 58376
Peter A. Talevich, WSBA No. 42644
Tyler K. Lichter, WSBA No. 51090
Emaan R. Jaberi, WSBA No. 56990
[e-mail]
[e-mail]
[e-mail]
[e-mail]

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Attorneys for Plaintiff

ROBERT W. FERGUSON
Office of the Attorney General for the State of
Washington
By: s/ Scott M. Barbara
Scott M. Barbara, WSBA No. 20885
Aaron Williams, WSBA No. 46044
Assistant Attorneys General
[e-mail]
[e-mail]

Attorneys for Defendants

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STIPULATION AND ORDER FOR LIMITED
REOPENING OF DISCOVERY
(NO.: 3:16-CV-05993-BHS-DWC - 3

K&L GATES LLP

925 FOURTH AVENUE, SUITE 2900
SEATTLE, WA 98104-1158
TELEPHONE: [phone]
FACSIMILE: [phone]

CERTIFICATE OF SERVICE

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I hereby certify that on September 6, 2024, I electronically filed the foregoing document

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with the Clerk of the Court using the CM/ECF system, which will send notice to all parties and

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counsel of record.

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Dated at Seattle, Washington, on September 6, 2024.
s/ Monica A. Romero

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STIPULATION AND ORDER FOR LIMITED
REOPENING OF DISCOVERY
(NO.: 3:16-CV-05993-BHS-DWC - 4

K&L GATES LLP

925 FOURTH AVENUE, SUITE 2900
SEATTLE, WA 98104-1158
TELEPHONE: [phone]
FACSIMILE: [phone]