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Swift v. Icicle Seafoods, Inc.

United States District Court, W.D. Washington, Seattle

May 10, 2017

JEFFREY SWIFT, Plaintiff,
v.
ICICLE SEAFOODS, INC AND ICICLE VESSEL HOLDING, INC, Defendants.

          GARY W.M. BAUN Attorneys for Plaintiff.

          DAVID C. BRATZ, DANIEL J. PARK Attorneys for Defendants.

          CHRISTOPHER M. DAVIS, Attorneys for Plaintiff.

          STIPULATED MOTION AND ORDER TO CONTINUE DISCOVERY AND RELATED DEADLINES

          RICARDO S. MARTINEZ CHIEF UNITED STATES DISTRICT JUDGE.

         I. MOTION

         Subject to the Court's approval, Plaintiff Jeffrey Swift and Defendants Icicle Seafoods, Inc. and Icicle Vessel Holding, Inc., by and through their undersigned counsel, hereby stipulate to the continuance of the (1) deadline to disclose expert testimony and (2) deadline to note all discovery-related motions, established by this Court's Order Setting Trial Date and Related Dates (ECF No. 11). The Parties do not seek a continuance of the December 11, 2017 trial date or any other pre-trial deadlines at this time.

         II. STIPULATION

         1. This is a seaman's personal injury action for injuries allegedly sustained by Plaintiff Jeffrey Swift while employed by Icicle Seafoods, Inc. and in service of the vessel P/V R.M. THORSTENSEN.

         2. The Parties have worked in good faith to complete discovery and have diligently pursued discovery. The Parties have propounded multiple sets of written discovery requests and together produced over 900 pages of documents. On April 10, 2017, Plaintiff underwent medical examinations performed by medical experts of both Parties. Defendants deposed Plaintiff on April 12, 2017.

         3. The Parties have discussed the possibility of deposing additional crewmembers of the P/V R.M. THORSTENSEN and conducting an inspection of the vessel. These discovery items have been tentatively scheduled for June 2017.

         4. The Parties stipulate to the continuance of the deadline to disclose expert testimony from June 14, 2017 to July 14, 2017, and the deadline to note discovery-related motions from July 14, 2017 to August 11, 2017.

         5. The continuance of these deadlines will permit the Parties to complete several critical areas of fact discovery so they can evaluate the possibilities of settlement, mediation, or other ADR methods before incurring significant additional litigation costs associated with expert discovery and completing other areas of fact discovery.

         6. The Parties have not requested a previous continuance.

         7. The Parties do not request a continuance of the December 11, 2017 trial date or any other pre-trial deadlines set forth in the Court's Order Setting Trial ...


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