United States District Court, W.D. Washington
Attorneys for Plaintiff: Scott C. G. Blankenship, WSBA No.
21431 Jordan A. Taren, WSBA No. 50066 The Blankenship Law
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
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.
STATEMENT OF FACTS
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.
Plaintiff filed a Motion to Compel Answers to Discovery and
Production of Documents on July 6, 2017. Dkt. 15.
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.
September 6, the Parties held an additional discovery
conference in compliance with this Court's order.
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.
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.
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.