United States District Court, W.D. Washington, Seattle
& ASSOCIATES, PLLC Thomas Lether, Eric J. Neal, Counsel
HANSON, ATTORNEY AT LAW, PLLC, Joel Hanson, Counsel for
STIPULATED MOTION TO CONTINUE TRIAL DATE AND AMEND
Honorable Ricardo S. Martinez
Foremost Insurance Company Grand Rapids, Michigan
(“Foremost”) and Plaintiff Tabitha Williams
(collectively the “Parties”) submit this
Stipulated Motion to Continue Trial Date and Amend Case
the current Case Schedule, trial is set to begin on August
13, 2018. However, counsel for Defendant has another trial
scheduled to begin that same week, on August 14, 2018. That
matter is Gallagher v. Fire Insurance Exchange, in
Skagit County Super Court cause number 15-2-01710-4. That
Gallagher matter has been pending since 2015, has
included two unsuccessful mediations, and will be a seven day
addition and in light of this Court's ruling on summary
judgment, the Parties also stipulate to shorten the length of
this trial to five (5) days.
the Parties stipulate to continue the trial date to September
17, 2018, as well as the related pre-trial deadlines on the
Case Schedule. It is therefore respectfully requested that
the Court amend the Case Schedule for the reasons set forth
STATEMENT OF FACTS
commenced this action June 22, 2017, in King County Superior
Court. Docket at 1-2. Defendant Foremost removed this action
to United States District Court on July 21, 2017. Dkt. at 1.
then, both parties have filed Motions for Partial Summary
Judgment. Dkt. at 9 & 21. Plaintiff's Motion for
Partial Summary Judgment was granted on October 3, 2017. Dkt.
at 18. Defendant Foremost's Motion for Partial Summary
Judgment is currently pending before the Court.
for Defendant Foremost has trial scheduled for a different
matter that is set to begin on the very same week as this
matter. Declaration of Eric Neal. That matter is
Gallagher v. Fire Insurance Exchange, in Skagit
County Super Court cause number 15-2-01710-4. Neal Decl. That
case has been ongoing since 2015 and the parties have
previously conducted two unsuccessful mediations. Neal Decl.
As a result, it appears that the Gallagher matter
will proceed to trial as scheduled. Neal Decl.
has agreed to continue the trial date to September of 2018 as
a courtesy to Defendant.
reasons set forth herein, the Parties respectfully request
that the Court amend the current Case Schedule and ...