United States District Court, W.D. Washington, Tacoma
CLEAR CREEK RETIREMENT PLAN II LLC, a Washington limited liability company, Plaintiff,
FOREMOST INSURANCE COMPANY GRAND RAPIDS MICHIGAN, a Michigan corporation, Defendant.
& ASSOCIATES, PLLC Thomas Lether, Eric J. Neal, Counsel
ROGERS, KEE & CARD, P.S. Thomas J. Westbrook, Rogers, Kee
& Card, P.S. Counsel for Plaintiff.
STIPULATED MOTION AND ORDER TO AMEND CASE
B. Leighton United States District Judge.
Foremost Insurance Company Grand Rapids, Michigan
(“Foremost”) and Plaintiff Clear Creek Retirement
Plan II, LLC (collectively the “Parties”) submit
this Stipulated Motion to Amend Case Schedule.
Motion for Summary Judgment is currently pending before the
Court. Under the current Case Schedule, disclosure of expert
testimony is due on June 20, 2018. Depending on the
Court's ruling on summary judgment, expert testimony may
not be required. Therefore, the Parties are stipulating to
amend the case schedule and extend the discovery deadlines.
expert disclosure deadline is extended sixty (60) days, the
extension would compromise other related discovery deadlines.
As a result, the Parties stipulate to the 60-day extension of
other related discovery deadlines.
therefore respectfully requested that the Court amend the
Case Schedule for the reasons set forth herein.
STATEMENT OF FACTS
commenced this action July 3, 2017, in Pierce 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, Foremost filed its Motion for Partial Summary Judgment
seeking dismissal of Plaintiffs IFCA claim. Dkt. at 11.
Defendant Foremost's Motion for Partial Summary Judgment
is currently pending before the Court.
order to potentially avoid incurring the cost of expert
witnesses, the Parties stipulate to the extension of FRCP
26(a)(2) deadline by 60 days, along with the other related
discovery deadlines. Extension of the expert deadline would
conflict the other discovery deadlines, specifically the
deadlines for discovery related motions and completion of
discovery. As a result, the Parties stipulate to the
extensions of the following deadlines by 60 days:
• Disclosure of expert testimony under FRCP ...