Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Cisneros v. Truckvault, Inc.

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

January 18, 2018

GUADALUPE CISNEROS, an individual, Plaintiff,
v.
TRUCKVAULT, INC., a Washington corporation, and JEFFREY RUSSELL, an individual, Defendants.

          Talia Y. Stoessel, WSBA Attorneys for Plaintiff Guadalupe

          Patrick S. Pearce, Attorneys for Defendant TruckVault, Inc.

          FOURTH JOINT STIPULATED MOTION AND ORDER EXTENDING DISCOVERY DEADLINES AND TRIAL DATE

          Marsha J. Pechman United States District Judge

         Pursuant to FRCP 16(b)(4) and LCR 16(b)(4), undersigned counsel for Plaintiff Guadalupe Cisneros and Defendants TruckVault, Inc. and Jeffrey Russell, and subject to the Court's approval, hereby renew their agreed stipulated motion to extend by 60 days the deadlines for discovery and trial date set forth in the Court's November 6, 2017 Order to Allow Second Joint Stipulated Motion for Extension of Time for Discovery Deadlines and Trial Setover. As the parties noted in their third stipulated motion, this extension is necessitated by unforeseen circumstances that delayed previously scheduled depositions scheduled for December 2017 and subsequent scheduling issues for counsel and the deponents. See Dkt. No. 19.

         In sum, due to an unexpected family emergency for Defendants' counsel, the parties cancelled the depositions scheduled for mid-December and were forced to reschedule. Dkt. No.20 (Declaration of Patrick Pearce in Support of Third Stipulated Motion and [Proposed] Order Extending Discovery Deadlines and Trial Date). Seven depositions needed to be rescheduled: six defense deponents and the Plaintiff. Declaration of Patrick Pearce in Support of Third Stipulated Motion and [Proposed] Order Extending Discovery Deadlines and Trial Date (“Pearce Decl.”) at ¶ 3. Because Plaintiff's counsel is located in Portland, Oregon, and will be traveling to Burlington, Washington to depose six defense deponents, and to Seattle, Washington to defend the deposition of Plaintiff, the parties agreed to schedule multi-day periods to facilitate multiple depositions in single trip for Plaintiff's counsel. Pearce Decl. at ¶ 3. Plaintiff's counsel is unavailable January 10-17, 2018, January 23, 2018, February 1-2, 2018, and February 6-23, 2018. Declaration of Talia Y. Stoessel in Support of Fourth Joint Stipulated Motion for Extension of Time for Discovery Deadlines (“Stoessel Decl.”) at ¶¶ 3-4. In email correspondence regarding scheduling, Plaintiff's counsel also indicated she was possibly unavailable on January 25-26, 2018. Pearce Decl. at ¶ 4. Plaintiff's counsel's unavailability in February is primarily the result of counsel's need to care for an immediate family member following an intensive surgery that has already been rescheduled once. Stoessel Decl. at ¶ 3.

         The parties agreed to schedule the depositions of four defense deponents over a two-day period, January 30-31, 2018 in Burlington, Washington. Pearce Decl. at ¶ 6. Notices for those depositions have been issued. Pearce Decl. at ¶ 6. However, two defense deponents were unavailable at the end of January and beginning of February because of preplanned out-of-state travel. Pearce Decl. at ¶ 7. Due to the preplanned travel of the two unavailable defense deponents and Plaintiff's work schedule, the parties determined that the next available two-day period was February 27-28, 2018, and agreed to schedule the remaining depositions over those two days. Pearce Decl. at ¶ 7. Notices for those depositions have been issued. Pearce Decl. at ¶ 7.

         To ensure that depositions can be completed as scheduled and noticed, and that the parties have an adequate amount of time following the depositions to file any necessary discovery related-motions and conduct follow-up discovery, the parties now seeking a 60-day extension of the discovery deadlines and trial date. Accordingly, the parties stipulate as follows:

• Disclosure of expert testimony under FRCP 26(a)(2): March 1, 2018
• Deadline for filing motions related to discovery. April 2, 2018
• Discovery completed by: May 2, 2018
• All dispositive motions must be filed by and noted on the motion calendar no later than the fourth Friday thereafter (see LCR 7(d)): May 25, 2018
• Mediation per LCR 39.1(c)(3), if requested by the parties, held no later than: July 13, 2018
• All motions in limine must be filed by and noted on the motion calendar no later than the THIRD Friday ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.