Stepien v. Raimondo

Opinion

The Honorable John C. Coughenour

UNITED STATES DISTRICT COURT FOR THE AT SEATTLE CAROL A. STEPIEN, CASE NO. 2:21-cv-01410-JCC

Plaintiff, STIPULATED MOTION FOR v. EXTENSION OF TIME TO RESPOND TO AMENDED COMPLAINT GINA RAIMONDO, SECRETARY, UNITED STATES

DEPARTMENT OF COMMERCE; UNITE STATES NOTING DATE: DEPARTMENT OF COMMERCE; NATIONAL December 16, 2021 OCEANIC AND ATMOSPHERIC ADMINISTRATION, ALSO KNOWN AS NOAA;

Defendants. Pursuant to Fed. R. Civ. P. 6 and Local Rules 10(g) and 16, and hereby jointly stipulate and move for an extension of 30 days for Defendants to answer or otherwise respond to the Amended Complaint to February 2, 2022. Defendants’ responsive pleading to the Complaint is currently due January 3, 2022. A court may modify a deadline for good cause. Fed. R. Civ. P. 6(b). Continuing pretrial and trial dates is within the discretion of the trial judge. See King v. State of California, 784 F.2d 910, 912 (9th Cir. 1986). The parties submit there is good cause for an extension of the deadlines. Defendants require additional time to review the allegations with the agency and prepare a response to be reviewed by the agency, which is difficult to coordinate with schedules over the upcoming holiday season. An extension of time to respond to the Amended Complaint will permit that review.

Stipulated to and presented this 16th day of December, 2021.

NICHOLAS W. BROWN NOLAN LIN LAW FIRM , PS United States Attorney s/ James C. Strong s/ Nolan Lim JAMES C. STRONG, OR # 131597 NOLAN LIM, WSBA # 36830 Assistant United States Attorney Nolan Lin Law Firm, PS United States Attorney’s Office 1111 Third Ave., Suite 1850 700 Stewart Street, Suite 5220 Seattle, Washington 98101 Seattle, Washington 98101-1271 Phone: (206) 774-8874 Phone: 206-553-7970 Email: nolan@nolanlimlaw.com Fax: 206-553-4067 Email: james.strong@usdoj.gov Counsel for Defendants Counsel for Plaintiff

The parties having stipulated and agreed, it is hereby so ORDERED. Defendants may have until to February 2, 2022, to answer or otherwise respond to the Amended Complaint. Dated this 20th day of December 2021. A John C. Coughenour UNITED STATES DISTRICT JUDGE