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Ltd. v. Rampion USA Inc.

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

August 2, 2019

0912139 B.C., LTD., a Canadian corporation, and PARAGE APPAREL, PNC., a Canadian corporation, Plaintiffs,
v.
RAMPION USA INC., a Washington corporation, and RAMPION ENTERPRISES LTD., a Canadian corporation, Defendants.

          Erin Kolter, Steven T. Lovett, Nathan C. Brunette Attorneys for Plaintiffs

          Steven T. Lovett, Nathan C. Brunette Attorneys for Defendants nathan.

          STIPULATED MOTION TO EXTEND CERTAIN PRETRIAL DATES AND [PROPOSED] ORDER

          HONORABLE JAMES L. ROBART JUDGE

         Pursuant to LCR 7(d)(1) and 10(g), Plaintiffs and Defendants, by and through their counsel of record, hereby stipulate and jointly move the Court for entry of an order extending certain pretrial deadlines.

         A. Case Status.

         This case was filed on October 5, 2018. (Dkt. #1.) On December 13, 2018, the Court entered its Minute Order Setting Trial Dates and Related Dates. (Dkt. #22.) The case schedule established in December was amended on January 23, 2019 to add two deadlines relating to certain patent-related disclosures. (Dkt. #25). No. further change to the case schedule has been requested or made.

         The parties have exchanged discovery requests and responses, tens of thousands of documents were produced, and one deposition was taken. The Court's Claim Construction Order was entered on July 30, 2019. (Dkt. #57.)

         B. Ongoing Settlement Efforts and August 21, 2019 Mediation.

         Over the last several weeks, the CEOs of the parties met in person and via telephone to discuss possible settlement and exchanged a series of detailed correspondence, including at least one exploratory offer of settlement. Mediation is scheduled to begin at 9 a.m. on Wednesday, August 21, 2019 with Lou Peterson, Mediator, at the offices of Hillis Clark Martin & Peterson P.S., 999 Third Avenue, Suite 4600, Seattle, Washington 98104.

         C. Cause for the Requested Extension.

         The parties seek to move the expert deadlines to avoid incurring the expense associated with expert work that would prove unnecessary if mediation succeeds. The parties also seek to move the close of discovery back three weeks to allow them to focus on preparing for a successful mediation between now and August 21, 2019, and to provide sufficient time following expert reports to complete discovery. All other pre-trial and trial dates remain in accordance with the Court's December 13, 2018 Minute Order.

         D. Requested Extension.

         Those deadlines "that" are the subject of this motion are bold and in italics in the below.

PRETRIAL DEADLINE

CURRENT DATE

PROPOSED DATE

Expert Witness Disclosure

08/30/2019

09/27/2019

Rebuttal Expert Disclosure

09/27/2019

10/18/2019

Amended Pleadings

10/02/2019 .

10/02/2019

Close of Discovery

10/18/2019

11/08/2019

Dispositive Motions

11/26/2019

11/26/2019


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