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Shokri v. The Boeing Co.

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

October 19, 2017

BEHROUZ SHOKRI, Plaintiff,
v.
THE BOEING COMPANY, Defendant.

          MORGAN, LEWIS & BOCKIUS, LLP Clifford D. Sethness MORGAN, LEWIS & BOCKIUS LLP Lincoln O. Bisbee (pro hac vice) MORGAN, LEWIS & BOCKIUS LLP Laurence A. Shapero, FOX ROTHSCHILD LLP Attorneys for Defendant The Boeing Company

          THE BLANKENSHIP LAW FIRM, P.S. Scott C. G. Blankenship Jordan A. Taren THE BLANKENSHIP LAW FIRM, P.S. Attorneys for Plaintiff Behrouz Shokri

          STIPULATED MOTION TO CONTINUE DISPOSITIVE MOTIONS AND PRETRIAL DEADLINES AND TRIAL DATE

          RICARDO S. MARTINEZ, CHIEF UNITED STATES DISTRICT JUDGE.

         Pursuant to Federal Rule of Civil Procedure 16, and Local Rule 16(b)(4), Plaintiff Behrouz Shokri and Defendant The Boeing Company (collectively, “the Parties”), respectfully move for a limited continuance of the trial date and certain related dates. This is the first continuance that the parties have sought. The Parties have conferred and jointly represent that good cause exists for this extension. In support, the Parties state as follows:

         A. STATEMENT OF FACTS

         1. Under the Court's Order Setting Trial Date and Related Dates (Dkt. 12), this case is currently subject to the following remaining deadlines:

a. Dispositive motion deadline: October 24, 2017
b. Motions in limine deadline: December 26, 2017
c. Agreed pretrial order due: January 10, 2018
d. Pretrial conference: January 10, 2018
e. Trial briefs, proposed voir dire questions, jury instructions, neutral statement of the case, and trial exhibits due: January 10, 2018
f. Jury trial (5-10 days): January 22, 2018

         2. As a general matter, discovery recently closed on September 25, 2017. However, pursuant to court-approved stipulations, as well as the Court's recent ruling on September 29, certain discovery matters remain to be completed.

         3. First, on September 29, 2017, the Court granted in part Boeing's Motion to Compel. The Court also directed Plaintiff to reappear for a continued (2-hour) deposition by no later than October 20, 2017. Due to various scheduling conflicts, the ...


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