Stepien v. Raimondo ( 2021 )

1 The Honorable John C. Coughenour 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT FOR THE 9 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 10 CAROL A. STEPIEN, CASE NO. 2:21-cv-01410-JCC 11 Plaintiff, 12 STIPULATED MOTION FOR v. EXTENSION OF TIME TO RESPOND 13 TO AMENDED COMPLAINT GINA RAIMONDO, SECRETARY, UNITED STATES DEPARTMENT OF COMMERCE; UNITE STATES 14 NOTING DATE: DEPARTMENT OF COMMERCE; NATIONAL December 16, 2021 OCEANIC AND ATMOSPHERIC 15 ADMINISTRATION, ALSO KNOWN AS NOAA; 16 Defendants. 17 18 Pursuant to Fed. R. Civ. P. 6 and Local Rules 10(g) and 16, and hereby jointly stipulate and 19 move for an extension of 30 days for Defendants to answer or otherwise respond to the Amended 20 Complaint to February 2, 2022. Defendants’ responsive pleading to the Complaint is currently due 21 January 3, 2022. 22 A court may modify a deadline for good cause. Fed. R. Civ. P. 6(b). Continuing pretrial and 23 trial dates is within the discretion of the trial judge. See King v. State of California, 784 F.2d 910, 912 24 (9th Cir. 1986). 1 The parties submit there is good cause for an extension of the deadlines. Defendants require 2 additional time to review the allegations with the agency and prepare a response to be reviewed by the 3 agency, which is difficult to coordinate with schedules over the upcoming holiday season. An 4 extension of time to respond to the Amended Complaint will permit that review. 5 6 Stipulated to and presented this 16th day of December, 2021. 7 NICHOLAS W. BROWN NOLAN LIN LAW FIRM , PS United States Attorney 8 s/ James C. Strong s/ Nolan Lim 9 JAMES C. STRONG, OR # 131597 NOLAN LIM, WSBA # 36830 Assistant United States Attorney Nolan Lin Law Firm, PS 10 United States Attorney’s Office 1111 Third Ave., Suite 1850 700 Stewart Street, Suite 5220 Seattle, Washington 98101 11 Seattle, Washington 98101-1271 Phone: (206) 774-8874 Phone: 206-553-7970 Email: nolan@nolanlimlaw.com 12 Fax: 206-553-4067 Email: james.strong@usdoj.gov 13 Counsel for Defendants Counsel for Plaintiff 14 15 16 17 18 19 20 21 22 23 24 1 ORDER 2 The parties having stipulated and agreed, it is hereby so ORDERED. Defendants may have 3 until to February 2, 2022, to answer or otherwise respond to the Amended Complaint. 4 Dated this 20th day of December 2021. 5 A 6 7 8 John C. Coughenour UNITED STATES DISTRICT JUDGE 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24