1 The Honorable James L. Robart 2 3 4 5 6 4 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON g AT SEATTLE 9 || JOHNNY B. DELASHAW, JR., Case No. 2:18-cv-00537-JLR 10 Plaintiff, STIPULATED MOTION AND ORDER RE: LIMITED 11 v. INTERVENTION BY DR. ROD OSKOUIAN 12 || SEATTLE TIMES COMPANY, and CHARLES 13 COBBS, NOTE ON MOTION CALENDAR: Defendants. July 27, 2020 14 15 Dr. Rod Oskouian (“Dr. Oskouian”) respectfully requests that this Court allow him to 16 || intervene in this action under Fed R. Civ. P. 24 as in interested party solely for the limited 17 || purpose of addressing the potential use of materials Dr. Oskouian designated as confidential 18 || under the stipulated protective order in this case. Dkt. 45-1; 46. Dr. Cobbs has filed two 19 || motions to seal that include materials Dr. Oskouian designated as confidential: (1) Motion to 20 || Seal in conjunction with Dr. Cobbs’s Second Motion for Summary Judgment (Dkt. 205); and (2) 21 |} Motion to Seal in Conjunction with Dr. Cobbs’s Motions in Limine (Dkt. 214). Dr. Oskouian 22 || seeks to intervene at this time only to address those motions. Counsel for all parties have 23 || conferred and stipulated to Dr. Oskouian’s request for limited intervention. In so stipulating, 24 || counsel for the parties here stipulate only to Dr. Oskouian’s request for limited intervention to be 25 || heard on Dr. Cobbs’ motion to seal, not to any arguments made about keeping any documents 26 || out of the open court file. Dr. Delashaw, Dr. Cobbs, and the Seattle Times expressly state, and
STIPULATED MOTION AND ORDER - RE: LIMITED INTERVENTION BY DR. ROD OSKOUIAN - 1 POLSINELLI (Case No. 2:18-cv-00537-JLR) 1000 SECOND AVENUE, SUITE 3500 SEATTLE, WA 98104 * (206) 393-5400
1 || Dr. Oskouian acknowledges, that nothing in this stipulated motion is intended to impact any 2 || arguments the parties might have with respect to Dr. Cobbs’s motion to seal. 3 ARGUMENT 1. The Fed. R. Civ. P. 24(a) Standard for Intervention. 5 Under Fed. R. Civ. P. 24(a), the Court “must permit anyone to intervene who claims an 6 || interest relating to the property or transaction that is the subject of the action, and is so situated 7 || that disposing of the action may as a practical matter impair or impede the movant’s ability to 8 || protect its interest, unless existing parties adequately represent that interest.” Fed. R. Civ. P. 9 || 24(a)(2). A motion must be granted if: (1) the application is timely; (2) the applicant has a 10 || “significantly protectable” interest relating to the property or transaction that is the subject of the 11 |} action; (3) the applicant is so situated that the disposition of the action may, as a practical matter, 12 || impair or impede the applicant’s ability to protect that interest; and (4) the applicant’s interest is 13 || not adequately represented by the existing parties in the lawsuit. Southwest Center for 14 || Biological Diversity v. Berg, 268 F.3d 810, 817 (9th Cir. 2001). The Court’s evaluation is 15 || “guided primarily by practical considerations,” not technical distinctions. Jd. Dr. Oskouian 16 || asserts that his motion meets each of the four requirements. 17 |} 2. Dr. Oskouian is entitled to limited intervention to protect his confidentiality interest. 18 a. Timeliness 19 The Seattle Times subpoenaed Dr. Oskouian to provide deposition testimony. Dr. 20 |} Oskouian was deposed pursuant to that subpoena on June 12, 2020. At the conclusion of that 21 || deposition, Dr. Oskouian’s counsel designated the transcript as confidential, as provided under 22 || the stipulated protective order. On July 9, 2020, after discussion with defendants’ counsel, Dr. 23 || Oskouian confirmed by page and line a more specific list of portions of the transcript to be 24 || designated as confidential. 25 The protective order and this Court’s rules require a party filing confidential material to 26 || confer with the designating party to determine whether the designating party will withdraw the
STIPULATED MOTION AND ORDER - RE: LIMITED INTERVENTION BY DR. ROD OSKOUIAN — 2 POLSINELLI (Case No. 2:18-ev-00537JLR) SEATTLE, WA 98 104 (306) 398-5400
1 || confidential designations before filing. Dr. Cobbs’s counsel and Dr. Oskouian’s counsel had 2 || several conversations regarding confidentiality designations, but were unable to resolve their 3 || differences. 4 Dr. Cobbs then filed on July 13, 2020, his motion to seal in conjunction with his Second 5 || Motion for Summary Judgment. (Dkt. 205). Dr. Oskouian now timely seeks to intervene to 6 || protect his confidentiality interest just two weeks after the motion to seal was filed. 7 b. Significant Protectable Interest. 8 An applicant for intervention has a “significant protectable interest” in an action if (1) it 9 || asserts an interest that is protected under some law, and (2) there is a “relationship” between its 10 || legally protected interest and the plaintiff's claims. Donnelly v. Glickman, 159 F.3d 405, 409 11 |} (th Cir. 1998) (citing Northwest forest Resource Council v. Glickman, 82 F.3d 825, 837 (9th 12 |} Cir. 1996)). “An applicant generally satisfies the ‘relationship’ requirement only if the 13 || resolution of the plaintiff's claims actually will affect the applicant.” Donnelly, 159 F.3d at 410 14 |} (citing Montana vy. United States Envtl. Protection Agency, 137 F.3d 1135, 1141-42 (9th Cir. 15 || 1998)). 16 Dr. Oskouian contends that he “asserts an interest that is protected under some law” 17 || because he argues that the materials he designated as confidential implicate his constitutionally- 18 || protected rights and his due process rights under the stipulated protective order entered under 19 || Fed. R. Civ. P. 26. 20 Likewise, Dr. Oskouian contends there is a “relationship” between Dr. Oskouian’s legally 21 || protectable confidentiality interest and the claims and defenses in the suit because Dr. Cobbs has 22 || relied on material Dr. Oskouian designated as confidential in support of his Second Motion for 23 |} Summary Judgment. This Court’s LCR 5(g) actually provides that it is incumbent upon the party 24 || designating materials as confidential under a stipulated protective order to satisfy this Court’s 25 || local rules to confirm that the material should be sealed from the public record. See LCR 26 || 5(g)(3)(B) Cwhere parties have entered a. . . stipulated protective order . . . the party who
STIPULATED MOTION AND ORDER - RE: LIMITED INTERVENTION BY DR. ROD OSKOUIAN - 3 POLSINELLI (Case No. 2:18-ev-00537JLR) SEATTLE, WA 98 104 (306) 398-5400
1 || designated the document confidential must satisfy subpart 3(B) in its response to the motion to 2 || seal or in a stipulated motion.”). Dr. Oskouian therefore respectfully submits that LCR 5(g) 3 || firmly establishes that there is a relationship between Dr. Oskouian’s confidentiality interest and 4 || the claims and defenses at issue here, specifically including Dr. Cobbs’s Second Motion for 5 || Summary Judgment. 6 c. Effect of Disposition on Dr. Oskouian’s Ability to Protect His Interest. 7 Although Dr.
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1 The Honorable James L. Robart 2 3 4 5 6 4 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON g AT SEATTLE 9 || JOHNNY B. DELASHAW, JR., Case No. 2:18-cv-00537-JLR 10 Plaintiff, STIPULATED MOTION AND ORDER RE: LIMITED 11 v. INTERVENTION BY DR. ROD OSKOUIAN 12 || SEATTLE TIMES COMPANY, and CHARLES 13 COBBS, NOTE ON MOTION CALENDAR: Defendants. July 27, 2020 14 15 Dr. Rod Oskouian (“Dr. Oskouian”) respectfully requests that this Court allow him to 16 || intervene in this action under Fed R. Civ. P. 24 as in interested party solely for the limited 17 || purpose of addressing the potential use of materials Dr. Oskouian designated as confidential 18 || under the stipulated protective order in this case. Dkt. 45-1; 46. Dr. Cobbs has filed two 19 || motions to seal that include materials Dr. Oskouian designated as confidential: (1) Motion to 20 || Seal in conjunction with Dr. Cobbs’s Second Motion for Summary Judgment (Dkt. 205); and (2) 21 |} Motion to Seal in Conjunction with Dr. Cobbs’s Motions in Limine (Dkt. 214). Dr. Oskouian 22 || seeks to intervene at this time only to address those motions. Counsel for all parties have 23 || conferred and stipulated to Dr. Oskouian’s request for limited intervention. In so stipulating, 24 || counsel for the parties here stipulate only to Dr. Oskouian’s request for limited intervention to be 25 || heard on Dr. Cobbs’ motion to seal, not to any arguments made about keeping any documents 26 || out of the open court file. Dr. Delashaw, Dr. Cobbs, and the Seattle Times expressly state, and
STIPULATED MOTION AND ORDER - RE: LIMITED INTERVENTION BY DR. ROD OSKOUIAN - 1 POLSINELLI (Case No. 2:18-cv-00537-JLR) 1000 SECOND AVENUE, SUITE 3500 SEATTLE, WA 98104 * (206) 393-5400
1 || Dr. Oskouian acknowledges, that nothing in this stipulated motion is intended to impact any 2 || arguments the parties might have with respect to Dr. Cobbs’s motion to seal. 3 ARGUMENT 1. The Fed. R. Civ. P. 24(a) Standard for Intervention. 5 Under Fed. R. Civ. P. 24(a), the Court “must permit anyone to intervene who claims an 6 || interest relating to the property or transaction that is the subject of the action, and is so situated 7 || that disposing of the action may as a practical matter impair or impede the movant’s ability to 8 || protect its interest, unless existing parties adequately represent that interest.” Fed. R. Civ. P. 9 || 24(a)(2). A motion must be granted if: (1) the application is timely; (2) the applicant has a 10 || “significantly protectable” interest relating to the property or transaction that is the subject of the 11 |} action; (3) the applicant is so situated that the disposition of the action may, as a practical matter, 12 || impair or impede the applicant’s ability to protect that interest; and (4) the applicant’s interest is 13 || not adequately represented by the existing parties in the lawsuit. Southwest Center for 14 || Biological Diversity v. Berg, 268 F.3d 810, 817 (9th Cir. 2001). The Court’s evaluation is 15 || “guided primarily by practical considerations,” not technical distinctions. Jd. Dr. Oskouian 16 || asserts that his motion meets each of the four requirements. 17 |} 2. Dr. Oskouian is entitled to limited intervention to protect his confidentiality interest. 18 a. Timeliness 19 The Seattle Times subpoenaed Dr. Oskouian to provide deposition testimony. Dr. 20 |} Oskouian was deposed pursuant to that subpoena on June 12, 2020. At the conclusion of that 21 || deposition, Dr. Oskouian’s counsel designated the transcript as confidential, as provided under 22 || the stipulated protective order. On July 9, 2020, after discussion with defendants’ counsel, Dr. 23 || Oskouian confirmed by page and line a more specific list of portions of the transcript to be 24 || designated as confidential. 25 The protective order and this Court’s rules require a party filing confidential material to 26 || confer with the designating party to determine whether the designating party will withdraw the
STIPULATED MOTION AND ORDER - RE: LIMITED INTERVENTION BY DR. ROD OSKOUIAN — 2 POLSINELLI (Case No. 2:18-ev-00537JLR) SEATTLE, WA 98 104 (306) 398-5400
1 || confidential designations before filing. Dr. Cobbs’s counsel and Dr. Oskouian’s counsel had 2 || several conversations regarding confidentiality designations, but were unable to resolve their 3 || differences. 4 Dr. Cobbs then filed on July 13, 2020, his motion to seal in conjunction with his Second 5 || Motion for Summary Judgment. (Dkt. 205). Dr. Oskouian now timely seeks to intervene to 6 || protect his confidentiality interest just two weeks after the motion to seal was filed. 7 b. Significant Protectable Interest. 8 An applicant for intervention has a “significant protectable interest” in an action if (1) it 9 || asserts an interest that is protected under some law, and (2) there is a “relationship” between its 10 || legally protected interest and the plaintiff's claims. Donnelly v. Glickman, 159 F.3d 405, 409 11 |} (th Cir. 1998) (citing Northwest forest Resource Council v. Glickman, 82 F.3d 825, 837 (9th 12 |} Cir. 1996)). “An applicant generally satisfies the ‘relationship’ requirement only if the 13 || resolution of the plaintiff's claims actually will affect the applicant.” Donnelly, 159 F.3d at 410 14 |} (citing Montana vy. United States Envtl. Protection Agency, 137 F.3d 1135, 1141-42 (9th Cir. 15 || 1998)). 16 Dr. Oskouian contends that he “asserts an interest that is protected under some law” 17 || because he argues that the materials he designated as confidential implicate his constitutionally- 18 || protected rights and his due process rights under the stipulated protective order entered under 19 || Fed. R. Civ. P. 26. 20 Likewise, Dr. Oskouian contends there is a “relationship” between Dr. Oskouian’s legally 21 || protectable confidentiality interest and the claims and defenses in the suit because Dr. Cobbs has 22 || relied on material Dr. Oskouian designated as confidential in support of his Second Motion for 23 |} Summary Judgment. This Court’s LCR 5(g) actually provides that it is incumbent upon the party 24 || designating materials as confidential under a stipulated protective order to satisfy this Court’s 25 || local rules to confirm that the material should be sealed from the public record. See LCR 26 || 5(g)(3)(B) Cwhere parties have entered a. . . stipulated protective order . . . the party who
STIPULATED MOTION AND ORDER - RE: LIMITED INTERVENTION BY DR. ROD OSKOUIAN - 3 POLSINELLI (Case No. 2:18-ev-00537JLR) SEATTLE, WA 98 104 (306) 398-5400
1 || designated the document confidential must satisfy subpart 3(B) in its response to the motion to 2 || seal or in a stipulated motion.”). Dr. Oskouian therefore respectfully submits that LCR 5(g) 3 || firmly establishes that there is a relationship between Dr. Oskouian’s confidentiality interest and 4 || the claims and defenses at issue here, specifically including Dr. Cobbs’s Second Motion for 5 || Summary Judgment. 6 c. Effect of Disposition on Dr. Oskouian’s Ability to Protect His Interest. 7 Although Dr. Oskouian is not a party here and has no interest in the ultimate outcome of 8 || this lawsuit on its merits, Dr. Cobbs has filed a motion for summary judgment relying, in part, on 9 || materials Dr. Oskouian has designated as confidential. Because those confidential materials are 10 || now implicated in potentially public filings, unless Dr. Oskouian intervenes, Dr. Oskouian 11 || asserts that the disposition of this case will directly impact his privacy and other interests. 12 || Where the Court agrees that a non-party has a “significant protectable interest,” it should have 13 || “little difficulty concluding that the disposition of the case may, as a practical matter, affect it.” 14 || California ex rel. Lockyer v. U.S., 450 F.3d 436, 442 (2006) (the court found the movant had a 15 || “significant protectable interest” and therefore “we have little difficulty concluding that the 16 || disposition of this case may, as a practical matter, affect it.”). Given Dr. Oskouian’s asserted 17 || significant protectable interest vis-a-vis his privacy and reputational interests, this Court should 18 |} have no difficulty concluding that the disposition of this case, and particularly the motions to 19 || seal, without Dr. Oskouian’s intervention will impact Dr. Oskouian. 20 d. Dr. Oskouian’s interests are not adequately protected by the existing parties. 21 “In determining adequacy of representation, we consider whether the interest of a 22 || present party is such that it will undoubtedly make all the intervenor’s arguments; whether the 23 || present party is capable and willing to make such arguments; and whether the intervenor would 24 || offer any necessary elements to the proceedings that other parties would neglect.” People of 25 || State of California v. Tahoe Reg’! Planning Agency, 792 F.2d 775, 778 (9th Cir. 1986) (internal 26
STIPULATED MOTION AND ORDER - RE: LIMITED INTERVENTION BY DR. ROD OSKOUIAN - 4 POLSINELLI (Case No. 2:18-ev-00537JLR) SEATTLE, WA 98 104 (306) 398-5400
1 || citations omitted). “The applicant is required only to make a minimal showing that 2 || representation of its interests may be inadequate.” Id. 3 None of the actual parties to the lawsuit are situated such that they can adequately 4 || protect Dr. Oskouian’s individual privacy interests. Dr. Oskouian is a non-party, and has no 5 || connection to the litigants here. Dr. Oskouian exercised his individual right under the stipulated 6 || protective order to designate portions of his deposition testimony as confidential. Only Dr. 7 || Oskouian, therefore, is capable of adequately advancing arguments to sufficiently protect his 8 || asserted privacy interest. 9 CONCLUSION 10 For the foregoing reasons, Dr. Oskouian respectfully submits that his motion meets the 11 || Fed R. Civ. P. 24(a) standard for intervention, particularly for the limited purposes sought here. 12 || Dr. Oskouian therefore respectfully requests that this Court grant its stipulated motion to 13 || intervene for the limited purposes of addressing his interest in maintaining the confidentiality of 14 || certain documents. 15 Stipulated and agreed to this 27th day of July, 2020. 16 U7 POLSINELLI PC 18 By: /s/Jim J. Fredman Jim J. Fredman, WSBA# 30110 19 1000 Second Ave., Suite 3500 Seattle, WA 98104 20 Tel: (206) 393-5400 1 Email: jim.fredman @ polsinelli.com 22 By: 4s/Brian McEvoy Brian McEvoy (Pro Hac Vice Pending) 23 1201 W. Peachtree Street NW Suite 1100 24 Atlanta, GA 30309 25 Tel: (404) 253-6021 Email: bmcevoy @ polsinelli.com 26 Attorneys for Nonparty Dr. Oskouian STIPULATED MOTION AND ORDER - RE: LIMITED INTERVENTION BY DR. ROD OSKOUIAN — 5 POLSINELLI (Case No. 2:18-cv-00537-JLR) 1000 SECOND AVENUE, SUITE 3500 SEATTLE, WA 98104 * (206) 393-5400
1 HARRIGAN LEYH FARMER & THOMSEN LLP 2 /s/ Tyler L. Farmer Arthur W. Harrigan, Jr., WSBA No. 1751 3 Tyler L. Farmer, WSBA No. 39912 A Kristin E. Ballinger, WSBA No. 28253 Caitlin B. Pratt, WSBA No. 48422 5 999 Third Avenue, Ste. 4400 Seattle, WA 98104 6 Phone: (206) 625-8600 7 Attorneys for Plaintiff Johnny B. Delashaw, Jr. 8 9 LAW OFFICES OF IRWIN H. SCHWARTZ 10 /s/ Irwin H. Schwartz 11 Irwin H. Schwartz, WSBA No. 4769 999 Third Avenue, Suite 4400 12 Seattle, WA 98104 B Telephone: (206) 676-7000 Fax: (206) 676-7001 14 irwin @ ihschwartz.com 15 Attorneys for Plaintiff Johnny B. Delashaw, Jr. 16 17 SUMMIT LAW GROUP PLLC 18 /s/Jessica L. Goldman 19 Jessica L. Goldman, WSBA No. 21856 Christopher T. Wion, WSBA No. 33207 20 Tanya Nesbitt, WSBA No. pending 4 315 Fifth Avenue South, Suite 1000 Seattle, WA 98104 22 Telephone: (206) 676-7000 Fax: (206) 676-7001 23 jessicag @ summitlaw.com chrisw@ summitlaw.com 24 tanyan@summitlaw.com 25 Attorneys for Defendant Seattle Times 26 Company
STIPULATED MOTION AND ORDER - RE: LIMITED INTERVENTION BY DR. ROD OSKOUIAN - 6 POLSINELLI (Case No. 2:18-cv-00537-JLR) 1000 SECOND AVENUE, SUITE 3500 SEATTLE, WA 98104 (206) 393-5400
1 2 McNAUL EBEL NAWROT & HELGREN PLLC 3 /s/ Malaika M. Eaton 4 Malaika M. Eaton, WSBA No. 32837 Jehiel I. Baer, WSBA No. 46951 5 600 University Street, Suite 2700 Seattle, WA 98101 6 Telephone: (206) 467-1816 7 meaton @ mcnaul.com jbaer@mcnaul.com 8 Attorneys for Defendant Charles Cobb 9 10 SOMERVILLE, LLC 11 /s/John_Q. Somerville 12 John Q. Somerville (admitted pro hac vice) 13 300 North Richard Arrington Blvd., Suite 710 Birmingham, AL 35203 14 Telephone: (205) 871-2183 jqgs@ somerville.com 15 6 Attorneys for Defendant Charles Cobb
17 18 ORDER 19 Pursuant to the parties’ stipulated motion, IT IS SO ORDERED. 20 21 DATED this 3rd day of August, 2020. 22 23 ( \ Pe YON 24 HONORABLE JAMES L. ROBART UNITED STATES DISTRICT JUDGE
STIPULATED MOTION AND ORDER - RE: LIMITED INTERVENTION BY DR. ROD OSKOUIAN — 7 POLSINELLI (Case No. 2:18-cv-00537-JLR) 1000 SECOND AVENUE, SUITE 3500 SEATTLE, WA 98104 (206) 393-5400
1 || Presented by: 2 || POLSINELLI PC 3 By: /s/Jim J. Fredman 4 || Jum J. Fredman, WSBA# 30110 1000 Second Ave., Suite 3500 5 || Seattle, WA 98104 Tel: (206) 393-5400 6 |) Email: jim.fredman @ polsinelli.com 7 By: /s/Brian McEvoy g || Brian McEvoy (Pro Hac Vice Pending) 1201 W. Peachtree Street NW, Suite 1100 9 || Atlanta, GA 30309 Tel: (404) 253-6021 10 || Email: bmcevoy @ polsinelli.com Attorneys for Nonparty Dr. Oskouian 12 13 |} HARRIGAN LEYH FARMER & THOMSEN LLP 14 || /s/ Tyler L. Farmer Arthur W. Harrigan, Jr., WSBA No. 1751 15 || Tyler L. Farmer, WSBA No. 39912 16 Kristin E. Ballinger, WSBA No. 28253 Caitlin B. Pratt, WSBA No. 48422 17 || 999 Third Avenue, Ste. 4400 Seattle, WA 98104 18 || Phone: (206) 625-8600 19 Attorneys for Plaintiff Johnny B. Delashaw, Jr. 20 21 LAW OFFICES OF IRWIN H. SCHWARTZ 22 /s/ Irwin H. Schwartz 23 || Irwin H. Schwartz, WSBA No. 4769 999 Third Avenue, Suite 4400 24 || Seattle, WA 98104 95 Telephone: (206) 676-7000 irwin @ihschwartz.com 26 Attorneys for Plaintiff Johnny B. Delashaw, Jr. STIPULATED MOTION AND ORDER - RE: LIMITED INTERVENTION BY DR. ROD OSKOUIAN - 8 POLSINELLI (Case No. 2:18-cv-00537-JLR) 1000 SECOND AVENUE, SUITE 3500 SEATTLE, WA 98104 (206) 393-5400
1 2 || SUMMIT LAW GROUP PLLC 3 |! A/Jessica L. Goldman 4 Jessica L. Goldman, WSBA No. 21856 Christopher T. Wion, WSBA No. 33207 5 || Tanya Nesbitt, WSBA No. pending 6 315 Fifth Avenue South, Suite 1000 Seattle, WA 98104 Telephone: (206) 676-7000 7 || jessicag@summitlaw.com chrisw@ summitlaw.com 8 || tanyan@summitlaw.com 9 Attorneys for Defendant Seattle Times Company 10 McNAUL EBEL NAWROT & HELGREN PLLC 12 /s/ Malaika M. Eaton 13 || Malaika M. Eaton, WSBA No. 32837 Jehiel I. Baer, WSBA No. 46951 14 | 600 University Street, Suite 2700 15 Seattle, WA 98101 Telephone: (206) 467-1816 16 || meaton@mcnaul.com jbaer@mcnaul.com 17 8 Attorneys for Defendant Charles Cobb
19 SOMERVILLE, LLC
20 /s/John O. Somerville John Q. Somerville (admitted pro hac vice) 21 |} 300 North Richard Arrington Blvd., Suite 710 Birmingham, AL 35203 22 || Telephone: (205) 871-2183 iqs@somerville.com 23 A Attorneys for Defendant Charles Cobb 25 26
STIPULATED MOTION AND ORDER - RE: LIMITED INTERVENTION BY DR. ROD OSKOUIAN - 9 POLSINELLI (Case No. 2:18-cv-00537-JLR) 1000 SECOND AVENUE, SUITE 3500 SEATTLE, WA 98104 (206) 393-5400
1 CERTIFICATE OF SERVICE 2 3 I hereby certify that on July 27, 2020, I caused the foregoing document to be served on
4 the counsel listed below via the CM/ECF system: 5 Attorneys for Plaintiff 6 Arthur W. Harrigan, Jr. arthurh @ harriganleyh.com Tyler L. Farmer tylerf@harriganleyh.com 7 Kristin E. Ballinger kristinb @ harriganleyh.com 8 John C. Burzynski caitlinp @ harriganleyh.com HARRIGAN LEYH FARMER & THOMSEN LLP kelliem @harriganleyh.com 9 999 Third Ave., Ste. 4400 florinef@ harriganleyh.com Seattle, WA 98104 10 i Attorneys for Plaintiff Irwin H. Schwartz irwin @ihschwartz.com LAW OFFICES OF IRWIN H. SCHWARTZ 13 999 Third Ave., Ste. 4400 Seattle, WA 98104 14 15 Attorneys for Defendant Charles Cobbs 16 Malaika M. Eaton meaton@mcnaul.com Jehiel I. Baer jbaer@mcnaul.com 17 MCNAUL EBEL NAWROT & HELGREN PLLC sredfield @mcnaul.com 600 University St., Ste. 2700 rlindsey@mcnaul.com 18 || Seattle, WA 98101 19 Attorneys for Defendant Charles Cobbs 20 John Q. Somerville JOS @Somervillellc.com 21 SOMERVILLE, LLC barbara @ somervillellc.com 300 Richard Arrington Jr. Blvd. N., Ste. 710 22 Birmingham, AL 35203 23 Attorneys for Defendant Seattle Times Company 24 Jessica L. Goldman jessicag @summitlaw.com 25 Christopher T. Wion chrisw @ summitlaw.com Tanya Nesbit tanuan@summitlaw.com 26 SUMMIT LAW GROUP, PLLC
STIPULATED MOTION AND ORDER - RE: LIMITED INTERVENTION BY DR. ROD OSKOUIAN — 10 POLSINELLI (Case No. 2:18-cv-00537-JLR) 1000 SECOND AVENUE, SUITE 3500 SEATTLE, WA 98104 (206) 393-5400
1 315 Fifth Avenue South, Suite 1000 Seattle, WA 98104-2682 I certify under penalty of perjury under the laws of the State of Washington that the ° foregoing is true and correct. ‘ DATED this 27" day of July, 2020, at Seattle. ° /s/Jeni Bonanno 6 Jeni Bonanno, Legal Assistant 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26
STIPULATED MOTION AND ORDER - RE: LIMITED INTERVENTION BY DR. ROD OSKOUIAN - 11 POLSINELLI (Case No. 2:18-ev-00537JLR) SEATTLE, WA 98104 (206) 398-5400