Filed: May 11, 2018
Latest Update: May 11, 2018
Summary: STIPULATED MOTION AND [REDACTED/] ORDER AMENDING CASE SCHEDULE FOR SOLE PURPOSE OF CONTINUING ONE OUT-OF-STATE 30(B)(6) DEPOSITION OF PROGRESSIVE MARSHA J. PECHMAN , District Judge . Pursuant to LCR 7(d)(1), LCR 10(g), and the Court's Chamber Procedures, plaintiff Ayanna Rosenberg, defendants CCS Commercial, LLC ("CCS"), and Progressive Direct Insurance Company ("Progressive"), by and through their counsel, hereby stipulate and move for a three-week continuance of the discovery deadline. S
Summary: STIPULATED MOTION AND [REDACTED/] ORDER AMENDING CASE SCHEDULE FOR SOLE PURPOSE OF CONTINUING ONE OUT-OF-STATE 30(B)(6) DEPOSITION OF PROGRESSIVE MARSHA J. PECHMAN , District Judge . Pursuant to LCR 7(d)(1), LCR 10(g), and the Court's Chamber Procedures, plaintiff Ayanna Rosenberg, defendants CCS Commercial, LLC ("CCS"), and Progressive Direct Insurance Company ("Progressive"), by and through their counsel, hereby stipulate and move for a three-week continuance of the discovery deadline. ST..
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STIPULATED MOTION AND [REDACTED/] ORDER AMENDING CASE SCHEDULE FOR SOLE PURPOSE OF CONTINUING ONE OUT-OF-STATE 30(B)(6) DEPOSITION OF PROGRESSIVE
MARSHA J. PECHMAN, District Judge.
Pursuant to LCR 7(d)(1), LCR 10(g), and the Court's Chamber Procedures, plaintiff Ayanna Rosenberg, defendants CCS Commercial, LLC ("CCS"), and Progressive Direct Insurance Company ("Progressive"), by and through their counsel, hereby stipulate and move for a three-week continuance of the discovery deadline.
STIPULATED MOTION
The parties agree and stipulate as follows:
The current discovery deadline is May 16, 2018. Plaintiff is scheduled to take a Rule 30(b)(6) deposition of Progressive on May 14, 2018.
Based on the parties' schedules and ongoing settlement negotiations, the parties have agreed to postpone the deposition of Progressive. The parties believe that a three-week continuance of the discovery deadline will provide sufficient time for plaintiff to complete the deposition of Progressive without disrupting the remaining case schedule.
Accordingly, the parties agree and stipulate that good cause exists to continue the discovery deadline for three weeks, for the sole purpose of completing the deposition of Progressive, to June 6, 2018.
STIPULATED and AGREED:
Dated this 10th day of May, 2018
TOUSLEY BRAIN STEPHENS PLLC BULLIVANT HOUSER BAILEY PC
By: /s/ Chase Alvord By: /s/ Matthew J. Sekits
Chase Alvord, WSBA No. 26080 Matthew J. Sekits, WSBA #26175
Email: calvord@tousley.com E-mail: matthew.sekits@bullivant.com
James M. Bulthuis, WSBA No. 44089 Holly D. Brauchli, WSBA #44814
Email: JBulthuis@Tousley.com E-mail: holly.brauchli@bullivant.com
IDE LAW OFFICE
Matthew James Ide, WSBA No. 26002 Attorneys for Defendant
Email: mjide@yahoo.com CCS Commercial, LLC
Attorney for Plaintiff Ayanna Rosenberg,
individually, and on Behalf of all those HOLLAND & KNIGHT
similarly situated
By: /s/ J. Matthew Donohue
J. Matthew Donohue, WSBA No. 52455
Email: matt.donohue@hklaw.com
Shannon Armstrong, WSBA No. 45947
Email: Shannon.armstrong@hklaw.com
Attorneys for Defendant Progressive Direct
Insurance Company
ORDER
Pursuant to the above stipulated motion, and good cause appearing, it is so ordered that the discovery deadline is extended to June 6, 2018, for the sole purpose of completing the deposition of Progressive, and that the Case Schedule be amended as indicated.
