STIPULATED MOTION AND ORDER TO EXTEND THE DEADLINES AND FOR A BRIEFING SCHEDULE ON THE MONITOR'S COMPLIANCE STATUS REPORT

(Please Note on Calendar for: September 8, 2017)

JAMES L. ROBART, District Judge.

Plaintiff, the United States of America, and Defendant, the City of Seattle (together, the "Parties"), respectfully move this Court to extend the deadline for the Parties to file their comments to the Monitor's Compliance Status Report ("Report") and to establish a briefing schedule, for the following reasons:

STIPULATION

Per the Court-approved Fourth Year Monitoring Plan, the Monitor and the Parties have been diligently and collaboratively discussing questions related to the significance of the Monitor's findings of "initial compliance" and how to measure sustained compliance, among other related questions. See Dkt. No. 294-1 at 22. These are complex and important questions.

The Monitor has indicated that he will file his Report on the same, on or before September 9, 2017. Dkt. No. 409. Today, the Court notified "all interested parties to file any comments concerning the Report no later than September 18, 2017." Dkt. No. 414.

As this Court is aware, the City is a multi-faceted entity. The City Attorney must obtain input from many stakeholders in the City family: the Mayor's Office, the Seattle Police Department, among others. Likewise, the United Department of Justice is a large, complex organization, with decision-makers on both coasts. Finally, the Community Police Commission ("CPC"), while not a party, is an important stakeholder granted amicus status in this matter, and is an entity that requires some time in developing its substantive policy or other substantive positions, in part because of its bi-monthly meeting schedule.1 Each of these entities requires more than ten days to respond to important deadlines in this matter.

Additionally, the Parties and CPC may benefit from additional time to discuss, amongst themselves and with the Monitor, the content of the Monitor's Report, whether to seek further clarification or to seek consensus on certain issues, so as to narrow any issues for the Court.

Finally, since the Defendant maintains the burden of showing compliance with the Decree (see Dkt. 3-1 ¶ 223), the Parties believe that a staggered briefing schedule would provide a more orderly and efficient presentation to the Court. See Dkt. 3-1 ¶ 223 ("At all times, the City and SPD will bear the burden of demonstrating substantial compliance with the Settlement Agreement.").

For these reasons, the Parties request additional time to complete those discussions and to prepare their respective responses to the Monitor's Report, and therefore respectfully and jointly move for the following briefing schedule:

The Monitor does not oppose on this request.

ORDER

The Parties having so stipulated, it is SO ORDERED.