Baker v. G&I VII Redmond Retail LLC ( 2019 )

I HONORABLE MARSHA J. PECHMAN 2 4 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON 9 AT SEATTLE 10 _ || BRIAN BAKER, a Washington resident, 12 Plaintiff, NO. 2:19-cv-01182-MJP 13 v. 14 || G&I VII REDMOND RETAIL LLC, a NEED ORDER NOR vr AY OF Delaware limited liability company, CASE FOR PENDING SETTLEMENT 15 NEGOTIATIONS Defendant. 16 NOTE ON MOTION CALENDAR: 7 Tuesday, October |, 2019 18 19 . STIPULATION 20 Plaintiff Brian Baker and Defendant G&I VII Redmond Retail, LLC (collectively, 21 ||“Parties”), by and through their respective undersigned attorneys, hereby move on a stipulated |land agreed basis for an order temporarily staying all litigation in this case while the Parties 23 |} engage in settlement negotiations. The parties are attempting to resolve this case at the earliest 24 || possible stage to secure the just, speedy, and inexpensive resolution of this action. See Fed. R. 25 ||Civ. P. 1. In support of the Stipulated Motion, the Parties jointly state as follows: GORDON REES SCULLY STIPULATED MOTION AND QD MANSUKHANT, LLP ORDER FOR STAY — PAGE 1 701 5th Avenue, Suite 2100 (Civil Action No. 2:19-cv-01182-MJP) Seattle, WA 98104 Telephone: 206.695.5100 Facsimile: 206.689.2822 1 1. On July 30, 2019, Plaintiff commenced this civil action by filing his Complaint. 2 ||Dkt. 1. Defendant has been served with process. 3 2. On October 1, 2019, the Parties through their counsel conferred regarding the 4 || possibility of resolving this case through settlement negotiations, including accessibility 5 alterations and the amount of reasonable attorney fees and costs, before undertaking significant 6 || litigation and motion practice. It appears that such a resolution is a likely possibility. 7 3. The Parties believe that they can informally exchange necessary information and 8 || engage in productive negotiations in 60 days. However, the Parties agree that these negotiations 9 || would be compromised by simultaneous discovery and motion practice. 10 Based on the foregoing, the Parties respectfully request the Court to enter an Order: 11 (i) Staying this action for all purposes until December |, 2019, to enable the parties to 12 || focus on and conduct settlement negotiations; and 13 (ii) Scheduling a date for the Parties to file a joint report or other event that will permit □ 14 |) the Parties to update the Court on progress of settlement efforts before or at the conclusion of the 15 || requested stay. 16 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 17 |) DATED: Oct. 1, 2019. GORDON REES SCULLY MANSUKHANI, LLP 18 By: Sarah N. Turner 19 Sarah N. Turner, WSBA #37748 Gordon Rees Scully Mansukhani, LLP 20 701 5th Avenue, Suite 2100 Seattle, Washington 98104 21 Tel: 206.695.5100 Email: Sturner@grsm.com 22 . Attorneys for Defendant 23 G&I VII REDMOND RETAIL LLC 24 25 . ‘ GORDON REES SCULLY STIPULATED MOTION AND MANSUKHANT, LLP ORDER FOR STAY — PAGE 2 701 Sth Avenue, Suite 2100 (Civil Action No. 2:19-cv-01182-MJP) Seattle, WA 98104 Telephone: 206.695.5100 Facsimile: 206.689.2822 1 ||} DATED: Oct. 1, 2019 WASHINGTON CIVIL & DISABILITY ADVOCATE 2 . By: /s/Michael Terasaki 3 Conrad Reynoldson, WSBA #48187 □ Michael Terasaki, WSBA # 4 Washington Civil & Disability Advocate 3513 NE 45" Street, Suite G 3 Seattle, Washington 98105 Tel.: 206.876.8515 6 Email: Conrad@wacda.com Teraskaki@wacda.com 7 Attorneys for Plaintiff 8 9 10 ORDER Il Based on the foregoing Stipulation, it is hereby ORDERED that this matter is stayed until 12 December 1, 2019. All case deadlines are extended until after December 1, 2019. It is further 13 ORDERED that the parties file a Joint Report regarding the progress of settlement negotiations 14 on or before December 1, 2019. 15 ard Dated this of October, 2019. 16 7 i} 19 HE HONORAB/E MARSHA J. PECHMAN 20 UNITED STATES DISTRICT JUDGE 21 22 23 24 25 GORDON REES SCULLY STIPULATED MOTION AND (Qa f MANSUKHANT, LLP ORDER FOR STAY — PAGE 3 701 5th Avenue, Suite 2100 (Civil Action No. 2:19-cv-01182-MIP) Seattle, WA 98104 Telephone: 206.695.5100 Facsimile: 206.689.2822 l CERTIFICATE OF SERVICE 2 The undersigned hereby certifies that on October 1, 2019, I electronically filed the 3 ||foregoing document entitled STIPULATED MOTION AND [PROPOSED] ORDER FOR 4 ||STAY OF CASE FOR PENDING SETTLEMENT NEGOTIATIONS with the Clerk of the 5 || Court using the CM/ECF system which will send notification of such filing to the following 6 || registered participants and party’s counsel of record: 7 Case Electronic Mail Notice List: e¢ Conrad Reynoldson 8 conrad@wacda.com; office@wacda.com 9 e Michael M Terasaki terasaki@wacda.com; michael@terasakilaw.com; felicity@wacda.com 10 DATED: October 1, 2019. 11 /s/ Estela Acosta 12 Estela Acosta, Legal Secretary 3 eacosta@grsm.com 14 15 16 17 18 19 20 21 22 23 24 25 GORDON REES SCULLY STIPULATED MOTION AND (aS MANSUKHANI, LLP ORDER FOR STAY—-PAGE4 701 Sth Avenue, Suite 2100 (Civil Action No. 2:19-év-01182-MJP) Seattle, WA 98104 Telephone: 206.695.5100 Facsimile: 206.689.2822