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Shokri v. The Boeing Co.

United States District Court, W.D. Washington

September 15, 2017

BEHROUZ SHOKRI, Plaintiff,
v.
THE BOEING COMPANY, a Delaware Corporation, Defendant.

          Attorneys for Plaintiff: Scott C. G. Blankenship, WSBA No. 21431 Jordan A. Taren, WSBA No. 50066 The Blankenship Law Firm, P.S.

          Attorneys for Defendant:Laurence A. Shapero, WSBA No. 31301 Fox Rothschild LLP, Clifford D. Sethness, WSBA No. 14110 Morgan, Lewis & Bockius LLP, Lincoln O. Bisbee, Admitted Pro Hac Vice Morgan Lewis & Blockius LLP

          STIPULATED MOTION AND ORDER TO EXTEND DEADLINE FOR PLAINTIFF'S DISCOVERY MOTION

          RICARDO S. MARTINEZ CHIEF UNITED STATES DISTRICT JUDGE

         1. Pursuant to FRCP 16, Plaintiff Behrouz Shokri and Defendant The Boeing Company (collectively, “the Parties”), respectfully request that the Court grant Plaintiff an additional week to file his discovery motion pursuant to this Court's August 24, 2017 Order on Plaintiff's Motion to Compel. The Parties have conferred and jointly represent that good cause exists for this extension, making Plaintiff's motion to compel due on September 22, 2017, so that Plaintiff can evaluate Defendant's recent supplementation to determine what issues remain to be heard by this Court.

         A. STATEMENT OF FACTS

         2. Plaintiff filed his Complaint for Damages on July 22, 2016. Dkt. 1. The current trial date is January 22, 2018, the discovery cutoff is September 25, 2017, and the deadline for filing discovery motions was August 25, 2017. Dkt. 12.

         3. Plaintiff filed a Motion to Compel Answers to Discovery and Production of Documents on July 6, 2017. Dkt. 15.

         4. On August 24, 2017, this Court denied Plaintiff's motion, but also ordered the following:

Further, the Court recognizes that the discovery motion deadline in this matter is August 25, 2017. . . Accordingly, should Plaintiff determine that a Motion to Compel is necessary after an additional conference with Defendant as directed in this Order, he will be allowed to file such a motion no later than September 15, 2017. Dkt. 42.

         5. On September 6, the Parties held an additional discovery conference in compliance with this Court's order.

         6. Defendant provided Plaintiff with supplemental production and supplemental answers on September 13. This gave Plaintiff insufficient time to adequately evaluate the remaining deficiencies and file a motion to compel by September 15, particularly because his Lead Counsel is in a deposition in this case, tomorrow, September 15.

         7. The Parties conferred on September 14, 2017, and have agreed that Plaintiff has good cause for a one-week extension to assess the remaining deficiencies and, in turn, to move the deadline for a motion to compel to September 22, 2017.

         8. The Parties also contacted the chambers of The Honorable Ricardo Martinez and spoke to the Docket Clerk to inform the Court that this stipulated motion was forthcoming.

         B. ...


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