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Espinoza v. The City of Seattle

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

December 12, 2017

DANIEL ESPINOZA, Plaintiff,
v.
THE CITY OF SEATTLE, WASHINGTON, and LIEUTENANT THOMAS MAHAFFEY, individually, Defendants.

          PETER S.HOLMES Seattle City Attorney DAVID BOWMAN, WSBA #28523 Assistant City Attorney Seattle City Attorney's Office Attorneys for Defendant City of Seattle

          LAW OFFICE OF THOMAS G. JARRARD, PLLC THOMAS G. JARRARD, WSBA #39774

          CROTTY & SON LAW FIRM, PLLC MATTHEW Z. CROTTY, WSBA #39284 Attorneys for Plaintiff

          PETER S.HOLMES Seattle City Attorney

          DAVID BOWMAN, WSBA #28523 Assistant City Attorney Seattle City Attorney's Attorneys for Defendant City of Seattle

          LAW OFFICE OF THOMAS G. JARRARD, PLLC THOMAS G. JARRARD, WSBA #39774

          CROTTY & SON LAW FIRM, PLLC MATTHEW Z. CROTTY, WSBA #39284

          Crotty & Son Law Firm, PLLC Attorneys for Plaintiff

          STIPULATION AND [PROPOSED] ORDER AMENDING ORDER REGARDING INITIAL DISCLOSURES AND JOINT STATUS REPORT [CLERK'S ACTION REQUIRED]

          Hon. James L. Robart Judge

         COME NOW the parties, Plaintiff Daniel Espinoza, represented by Thomas G. Jarrard and Matthew Z. Crotty, and Defendant City of Seattle, represented by Assistant City Attorney David Bowman, and stipulate to amendment of the Court's Order Regarding Initial Disclosures and Joint Status Report dated December 8, 2017, by establishing the following dates for initial disclosure and submission of the Joint Status Report and Discovery Plan:

Deadline for FRCP 26(f) Conference:

1/12/2018

Initial Disclosures Pursuant to FRCP 26(a)(1):

1/26/2018

Combined Joint Status Report and Discovery Plan as Required by FRCP 26(f) and Local Civil Rule 26(f):

2/2/2018

The parties make this request on the following grounds pursuant to Local Civil Rule 16(b)($: On December 5, 2017, by stipulation of the parties the Court ordered an extension time for Defendant City of Seattle to file its Answer to Plaintiffs Complaint, to January 5, 2018. Although the parties do not wish to cause any unnecessary delay to the case and are proceeding diligently to connect with witnesses and ascertain what documents will be needed to support their respective claims and defenses, Defendants need additional time to prepare for the Rule 26(f) initial discovery conference and initial disclosures due to the scope of potential witnesses, documents and information that must be identified and sought. The parties respectfully ask that the Court find good cause exists to modify its Order Regarding Initial Disclosures and Joint Status Report.

         ORDER

         Based on the foregoing stipulation of the parties and good ...


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