Filed: Jul. 30, 2019
Latest Update: Jul. 30, 2019
Summary: STIPULATED MOTION AND [PROPOSED] ORDER TO EXTEND DISCOVERY CUT-OFF FOR EXPERT WITNESS DEPOSITION JAMES L. ROBART , District Judge . Pursuant to Local Civil Rule 16(b)(5), and subject to the Court's approval, Plaintiffs California Expanded Metal Products Company ("CEMCO") and Clarkwestern Dietrich Building Systems LLC, d.b.a. ClarkDietrich Building Systems ("ClarkDietrich") (collectively "Plaintiffs"), and Defendants James A. Klein, BlazeFrame Industries, Ltd., and Safti-Seal, Inc. (co
Summary: STIPULATED MOTION AND [PROPOSED] ORDER TO EXTEND DISCOVERY CUT-OFF FOR EXPERT WITNESS DEPOSITION JAMES L. ROBART , District Judge . Pursuant to Local Civil Rule 16(b)(5), and subject to the Court's approval, Plaintiffs California Expanded Metal Products Company ("CEMCO") and Clarkwestern Dietrich Building Systems LLC, d.b.a. ClarkDietrich Building Systems ("ClarkDietrich") (collectively "Plaintiffs"), and Defendants James A. Klein, BlazeFrame Industries, Ltd., and Safti-Seal, Inc. (col..
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STIPULATED MOTION AND [PROPOSED] ORDER TO EXTEND DISCOVERY CUT-OFF FOR EXPERT WITNESS DEPOSITION
JAMES L. ROBART, District Judge.
Pursuant to Local Civil Rule 16(b)(5), and subject to the Court's approval, Plaintiffs California Expanded Metal Products Company ("CEMCO") and Clarkwestern Dietrich Building Systems LLC, d.b.a. ClarkDietrich Building Systems ("ClarkDietrich") (collectively "Plaintiffs"), and Defendants James A. Klein, BlazeFrame Industries, Ltd., and Safti-Seal, Inc. (collectively, "Defendants"), by and through their counsel of record, move the Court to extend Discovery cut-off to take a single expert witness deposition after the current discovery cut-off date of July 29, 2019. If granted, the requested extension will not affect any other deadline set by the Court. Good cause exists for the extension as follows.
STIPULATED MOTION TO EXTEND DISCOVERY CUT-OFF
Under the Court's current scheduling order, discovery is set to close today, July 29, 2019. The deposition of Defendants' expert witness, Dan Lindsay, was set to occur on July 29, 2019. Unfortunately, Mr. Lindsay became ill and informed the parties by email on Sunday, July 28, 2019, that he would not be available to be deposed as scheduled. See July 29, 2019, Bageant Decl. Exh. A. To allow Mr. Lindsay to recover from his illness, the parties agreed, subject to the Court's approval, to reschedule the deposition to August 1, 2019, in Houston, Texas. Thus, subject to the Court's approval, the Parties have stipulated to extending the deadlines for discovery to take Mr. Lindsay's deposition until August 1, 2019.
The requested extension will not affect the other dates in the case. The trial scheduled at the end of the year will also not be affected. Therefore, based on the foregoing, the parties respectfully request that the Court GRANT this stipulated motion.
Respectfully submitted,
TROJAN LAW OFFICES
by
July 29, 2019 /s/ R. Joseph Trojan
R. Joseph Trojan (pro hac vice)
9250 Wilshire Blvd.
Beverly Hills, CA
Attorney for Plaintiff,
CALIFORNIA EXPANDED METAL PRODUCTS
COMPANY
July 29, 2019 /s/ Brian G. Bodine
Brian G. Bodine (WSBA No. 22414)
LANE POWELL PC
1420 Fifth Avenue, Suite 4200
Seattle, WA 98111
Telephone: 206-223-7000
Attorney for Plaintiff,
CALIFORNIA EXPANDED METAL PRODUCTS
COMPANY
July 29, 2019 /s/ Ann G. Schoen
Ann G. Schoen (pro hac vice)
FROST BROWN TODD LLC
301 East Fourth Street, Suite 3300
Cincinnati, OH 45202
Telephone: 513-651-6128
Attorney for Plaintiff,
CLARKWESTERN DIETRICH BUILDING
SYSTEMS LLC
July 29, 2019 /s/ Robert J. Carlson
Robert J. Carlson (WSBA No. 18455)
LEE & HAYES PLLC
701 Pike Street, Suite 1600
Seattle, WA 98101
Telephone: 206-876-6029
Attorney for Plaintiff,
CLARKWESTERN DIETRICH BUILDING
SYSTEMS LLC
July 29, 2019 /s/ Patrick C. Bageant
Patrick C. Bageant (No. 44268)
HOLLYSTONE LAW
1775 West State Street, #286
Boise, ID 83702
Telephone: 208-596-5343
Thomas E Loop (No. 27546)
LOOP INTELLECTUAL PROPERTY LAW
1700 Seventh Avenue, Suite 2100
Seattle, WA 98101
Telephone: 206-568-3100
Thomas J. Lloyd, III (pro hac vice)
Greener Burke Shoemaker Oberrecht PA
950 West Bannock Street Suite 950
Boise, ID 83702
Telephone: 208-319-2600
Attorneys for Defendants.
ORDER
IT IS SO ORDERED.
