Johnson v. City of Olympia et al

Filing 25

STIPULATION AND ORDER FOR TRIAL CONTINUANCE AND NEW DISCOVERY SCHEDULE: Jury Trial CONTINUED to 10/15/2018 at 09:00 AM in Courtroom 14206 before Judge Marsha J. Pechman; Discovery Motions due by 4/18/2018, Discovery completed by 5/18/2018, Disposit ive motions due by 6/18/2018, Motions in Limine due by 9/10/2018, Agreed Pretrial Order due by 10/3/2018, Voir dire/jury instructions/trial briefs due by 10/3/2018, Pretrial Conference set for 10/5/2018 at 01:30 PM before Judge Marsha J. Pechman. Signed by Judge Marsha J. Pechman. (PM)

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Honorable Marasha J. Pechman

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

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TYRONE JOHNSON,
PLAINTIFF,

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CASE NO: 3:17-CV-05403-MJP

VS.
CITY OF OLYMPIA, CITY OF OLYMPIA
POLICE DEPARTMENT, RYAN DONALD
individually, in his official capacity and on
behalf of his marital community with his
spouse, Jane or John Doe (1) GEORGE
CLARK individually, in his official capacity,
and on behalf of his marital community with
his spouse, Jane or John Doe (2), JONATHAN
HAZEN individually, in his official capacity
and on behalf of his marital community with
his spouse, Jane or John Doe (3), ERIC
HENRICHSEN individually, in his official
capacity and on behalf of his marital
community with his spouse, Jane or John Doe
(4), MATTHEW RENSCLER individually, in
his official capacity, and on behalf of his
marital community with his spouse, Jane or
John Doe (5), RANDY WILSON individually,
in his official capacity, and on behalf of his
marital community with his spouse, Jane or
John Doe (6), DOES 7-12, ABC CORP., AND
XYZ CORP. (fictitious names whose identities
are presently unknown).

STIPULATION AND ORDER FOR
TRIAL CONTINUANCE AND NEW
DISCOVERY SCHEDULE

DEFENDANTS.

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STIPULATION TO EXTEND THE TRIAL DATE
AND CORRESPONDING DEADLINES

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BEVERLY GRANT LAW FIRM, P.S.
3929 Bridgeport Way W. Ste. 208
University Place, WA. 98464
235-252-5454

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IT IS HEREBY STIPULATED by and between Beverly Grant and Elizabeth Lunde, counsel

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for Plaintiff herein, and John Justice, counsel for Defendants herein, that the trial of the above entitled

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matter may be continued from July 23, 2018 to October 1, 2018, or others date as set by the Court,

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and a proposed continuance of remaining case deadlines as follows:

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Description

Current
Dates

Proposed
Dates

All motions related to discovery
must be filed by and noted on the
motion calendar on the third Friday
thereafter (see CR 7(d))
Discovery Completed by

1/24/18

3/23/18

2/23/18

4/27/18

All dispositive motions must be
filed by and noted on the motion
calendar on the fourth Friday
thereafter (see CR 7(d))
All motions in limine must be filed
by and noted on the motion calendar
no earlier than the third Friday
thereafter and no later than the
Friday
before
the
pretrial
conference
Agreed pretrial order due

3/26/18

5/25/18

6/18/18

8/17/18

7/11/18

9/17/18

Trial briefs, proposed voir dire
questions, and proposed jury
instructions:
Pretrial conference

7/11/18

9/17/18

7/13/18

Trial Date

7/23/18

Set by court
depending on
trial date
Set by court

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New Dates By
Order of the
Judge

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The primary reasons necessitating continuance are that Plaintiff’s counsel has been required
to address an emergent health issue requiring surgery that made completion of discovery difficult, if
not impossible, prior to the discovery cutoff of February 23, 2018. Plaintiff’s counsel, Elizabeth

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STIPULATION TO EXTEND THE TRIAL DATE
AND CORRESPONDING DEADLINES

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BEVERLY GRANT LAW FIRM, P.S.
3929 Bridgeport Way W. Ste. 208
University Place, WA. 98464
235-252-5454

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Lunde, was injured on November 4, 2017, which has caused delays and requires her to undergo

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surgery on January 5, 2018, which will entail a 6-week recovery period. Plaintiff’s counsel can

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provide the Court additional information regarding these medical issues, if requested.

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Stipulated to this 3rd day of January, 2018.
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BEVERLY GRANT LAW FIRM, P.S.
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/s/Elizabeth Lunde
Elizabeth G. Lunde, WSBA No. 51565
Beverly Grant, WSBA No. 8034
Attorneys for Plaintiff

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

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/s/John E. Justice
John E. Justice, WSBA No. 23042
Attorney for Defendant

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STIPULATION TO EXTEND THE TRIAL DATE
AND CORRESPONDING DEADLINES

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BEVERLY GRANT LAW FIRM, P.S.
3929 Bridgeport Way W. Ste. 208
University Place, WA. 98464
235-252-5454

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ORDER

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THIS MATTER having come on before the above-entitled court upon stipulation of

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counsel, the court having examined the records and being fully advised in the matter, now, therefore,

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IT IS HEREBY ORDERED that the trial of the above-entitled cause shall be continued

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from July 23, 2018 to October 15, 2018. The remaining dates are continued as follows:

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Description

Current
Dates

Proposed Dates

All motions related to discovery must
be filed by and noted on the motion
calendar on the third Friday thereafter
(see CR 7(d))
Discovery Completed by

1/24/18

3/23/18

New Dates By
Order of the
Judge
4/18/2018

2/23/18

4/27/18

5/18/2018

All dispositive motions must be filed by
and noted on the motion calendar on the
fourth Friday thereafter (see CR 7(d))
All motions in limine must be filed by
and noted on the motion calendar no
earlier than the third Friday thereafter
and no later than the Friday before the
pretrial conference
Agreed pretrial order due

3/26/18

5/25/18

6/18/2018

6/18/18

8/17/18

9/10/2018

7/11/18

9/17/18

10/3/2018

Trial briefs, proposed voir dire
questions,
and
proposed
jury
instructions:
Pretrial conference

7/11/18

9/17/18

10/3/2018

7/13/18

7/23/18

Set by court
depending on
trial date
Set by court

10/5/2018 at
1:30 PM

Trial Date

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10/15/2018 at
9:00 AM

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STIPULATION TO EXTEND THE TRIAL DATE
AND CORRESPONDING DEADLINES

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BEVERLY GRANT LAW FIRM, P.S.
3929 Bridgeport Way W. Ste. 208
University Place, WA. 98464
235-252-5454

DONE this 9th day of January, 2018.

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A

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Marsha J. Pechman
United States District Judge

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Presented by:

Approved as to form and notice of presentation
waived:

BEVERLY GRANT LAW FIRM, P.S.

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

/s/Elizabeth Lunde
Beverly Grant, WSBA No. 8034
Elizabeth Lunde, WSBA No. 51565
Attorneys for Plaintiff

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

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STIPULATION TO EXTEND THE TRIAL DATE
AND CORRESPONDING DEADLINES

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BEVERLY GRANT LAW FIRM, P.S.
3929 Bridgeport Way W. Ste. 208
University Place, WA. 98464
235-252-5454