United States District Court, W.D. Washington, Seattle
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
BLANKENSHIP LAW FIRM, P.S. Scott C. G. Blankenship Jordan A.
Taren THE BLANKENSHIP LAW FIRM, P.S. Attorneys for Plaintiff
STIPULATED MOTION TO CONTINUE DISPOSITIVE MOTIONS AND
PRETRIAL DEADLINES AND TRIAL DATE
RICARDO S. MARTINEZ, CHIEF UNITED STATES DISTRICT JUDGE.
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:
STATEMENT OF FACTS
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.
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 ...