Hoffman et al v. Transworld Systems Incorporated et al, No. 2:2018cv01132 - Document 121 (W.D. Wash. 2021)
Court Description: ORDER granting Parties' 120 Stipulated Motion Extending Certain Deadlines. Signed by Judge Thomas S. Zilly.(MW)
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Hoffman et al v. Transworld Systems Incorporated et al Doc. 121 Case 2:18-cv-01132-TSZ Document 121 Filed 01/22/21 Page 1 of 6 1 2 Hon. Thomas S. Zilly 3 4 5 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE 6 7 ESTHER HOFFMAN; et al., 8 No. 2:18 cv 1132-TSZ Plaintiffs, 9 10 11 STIPULATION AND ORDER EXTENDING RESPONSE TO THE COMPLAINT AND INITIAL DISCOVERY DATES v. TRANSWORLD SYSTEMS INCORPORATED; et al., 12 Defendants. 13 I. 14 15 16 17 18 19 20 21 22 23 24 STIPULATION In the Court’s Order on Defendants’ Motions to Dismiss (Dkt. 118) (the “Order”), this Court dismissed certain Defendants without prejudice and provided Plaintiffs thirty (30) days, to move to amend the pleadings. It could waste resources for the current Defendants to respond to the current Complaint, since Plaintiffs are considering filing a motion to amend the pleadings to add new defendants, so in the interests of judicial economy, the Parties stipulate as follows. 1. If Plaintiffs do not file a motion to amend the pleadings by February 3, 2021, then current Defendants will file a response to Plaintiffs’ Second Amended Complaint (Dkt. 61), by February 24, 2021. 2. If Plaintiffs do file a motion to amend the Pleadings by February 3, 2021, then current Defendants will file a response as follows: 25 STIPULATION AND ORDER EXTENDING RESPONSE TO THE COMPLAINT AND INITIAL DISCOVERY DATES - 1 2:18 cv 1132-TSZ Dockets.Justia.com Case 2:18-cv-01132-TSZ Document 121 Filed 01/22/21 Page 2 of 6 1 a. Within 21 days of any Order by this Court denying a motion to amend 2 the pleadings, or 3 b. Within 21 days of the filing by Plaintiffs of any Third Amended 4 Complaint, should Plaintiffs’ motion be granted. 5 3. The Parties also stipulate that any proposed amended complaint sought to be 6 filed by Plaintiffs will be limited to naming as additional defendants any National Collegiate 7 Student Loan Trust entities and adding facts to support the claims asserted against such entities, 8 pursuant to the juridical link doctrine. 9 4. The Parties further stipulate that, if Plaintiff is permitted to file an amended 10 pleading as outlined in paragraph 3 above, then any Fed. R. Civ. P. 12 motion to dismiss filed 11 by any then-current Defendant(s) will address only whether the juridical link doctrine supports 12 plausible claims for relief asserted against any National Collegiate Student Loan Trust entities 13 added as defendants in the Third Amended Complaint. 14 5. The Parties further stipulate that the Parties may immediately propound written 15 discovery pursuant to Fed. R. Civ. P. 26-37 to any current Party, and the normal rules of 16 discovery will apply. 17 6. The Parties also agree to extend the initial discovery dates, based on the dates of 18 filing of Answers by the Defendants. 19 a. 7 days after filing - Rule 26(a) Initial Disclosures 20 b. 14 days after filing - Rule 26(f) Conference 21 c. 21 days after filing - Joint Status Report and Discovery Plan 22 Jointly submitted this 19th day of January, 2021. 23 LEONARD LAW 24 25 s/ Sam Leonard _____________ Sam Leonard, WSBA #46498 STIPULATION AND ORDER EXTENDING RESPONSE TO THE COMPLAINT AND INITIAL DISCOVERY DATES - 2 2:18 cv 1132-TSZ Case 2:18-cv-01132-TSZ Document 121 Filed 01/22/21 Page 3 of 6 1 2 Attorney for Plaintiffs 4 3614 California Ave. SW, #151 Seattle, WA 98116 (206) 486-1176 sam@seattledebtdefense.com 5 BERRY & BECKETT, PLLP 3 6 7 s/ Guy W. Beckett __________________ Guy W. Beckett, WSBA #14939 Attorney for Plaintiffs 8 9 10 1708 Bellevue Avenue Seattle, WA 98122 (206) 441-5444 gbeckett@beckettlaw.com 11 HENRY & DeGRAAFF, P.S. 12 13 14 15 16 17 s/ Christina L. Henry_________________ Christina L. Henry, WSBA #31273 Attorney for Plaintiffs 787 Maynard Ave. S, Seattle, WA 98104 (206) 330-0595 chenry@HDM-legal.com 18 NORTHWEST CONSUMER LAW CENTER 19 s/ Amanda N. Martin ___________________ Amanda N. Martin, WSBA #49581 Attorney for Plaintiffs 20 21 22 23 936 North 34th Street, Suite 300 Seattle, WA 98103 (206) 805-0989 Amanda@NWCLC.org 24 25 STIPULATION AND ORDER EXTENDING RESPONSE TO THE COMPLAINT AND INITIAL DISCOVERY DATES - 3 2:18 cv 1132-TSZ Case 2:18-cv-01132-TSZ Document 121 Filed 01/22/21 Page 4 of 6 1 2 3 4 5 6 7 8 9 10 SESSIONS, ISRAEL & SHARTLE, LLC s/ Justin H. Homes _______________________ Bryan C. Shartle, Pro Hac Vice James K. Schultz Pro Hac Vice Justin H. Homes, Pro Hac Vice Attorneys for Defendants Transworld Systems Inc., and National Collegiate Student Loan Trusts 3850 North Causeway Blvd, Suite 200 Metairie, LA 70002-7227 (504) 828-3700 bshartle@sessions.legal jhomes@sessions.legal ANDREWS SKINNER, P.S. 11 12 13 14 s/ Stephen G. Skinner ___________________ Stephen G. Skinner, WSBA #17317 Transworld Systems Inc., and National Collegiate Student Loan Trusts 16 645 Elliott Ave. W., Suite 350 Seattle, WA 98119 206-223-9248 stephen.skinner@andrews-skinner.com 17 LEE SMART 15 18 19 20 21 22 23 24 s/ Marc Rosenberg _______________________ Marc Rosenberg, WSBA No. 31034 Attorney for Defendant Patenaude & Felix, APC, and Matthew Cheung 1800 One Convention Place 701 Pike St. Seattle, WA 98101-3929 (206) 624-7990 mr@leesmart.com 25 STIPULATION AND ORDER EXTENDING RESPONSE TO THE COMPLAINT AND INITIAL DISCOVERY DATES - 4 2:18 cv 1132-TSZ Case 2:18-cv-01132-TSZ Document 121 Filed 01/22/21 Page 5 of 6 1 II. ORDER 2 THIS MATTER having come before the Court upon stipulation by the plaintiffs and the 3 defendants, the Court having reviewed and considered the stipulation and all related pleadings 4 and documents on file in this case, NOW THEREFORE, IT IS HEREBY, ORDERED: 5 1. If Plaintiffs do not file a motion to amend the pleadings by February 3, 2021, 6 then current Defendants shall file a response to Plaintiffs’ Second Amended Complaint, (Dkt. 7 61), by February 24, 2021. 8 9 2. If Plaintiffs do file a motion to amend the Pleadings by February 3, 2021, then current Defendants will file a response as follows: 10 a. Within 21 days of any Order by this Court denying a motion to amend the 11 pleadings, or 12 b. Within 21 days of the filing by Plaintiffs of any Third Amended Complaint, 13 should Plaintiff’s motion be granted. 14 3. Any proposed amended complaint sought to be filed by Plaintiffs shall be 15 limited to naming as additional defendants any National Collegiate Student Loan Trust entities 16 and adding facts to support the claims asserted against such entities, pursuant to the juridical 17 link doctrine. 18 4. If Plaintiff is permitted to file an amended pleading as outlined in paragraph 3 19 above, then any Fed. R. Civ. P. 12 motion to dismiss filed by any then-current Defendant(s) 20 will address only whether the juridical link doctrine supports plausible claims for relief asserted 21 against any National Collegiate Student Loan Trust entities added as defendants in the Third 22 Amended Complaint. 23 24 5. The Parties may immediately propound written discovery pursuant to Fed. R. Civ. P. 26-37 to any current Party, and the normal rules of discovery will apply. 25 STIPULATION AND ORDER EXTENDING RESPONSE TO THE COMPLAINT AND INITIAL DISCOVERY DATES - 5 2:18 cv 1132-TSZ Case 2:18-cv-01132-TSZ Document 121 Filed 01/22/21 Page 6 of 6 1 6. Initial discovery dates shall be extended and shall be based on the filing of 2 Answers by the Defendants, as follows: 3 a. 7 days after filing - Rule 26(a) Initial Disclosures 4 b. 14 days after filing - Rule 26(f) Conference 5 c. 21 days after filing - Joint Status Report and Discovery Plan 6 7 Dated this 22nd day of January 2021. 8 9 11 A 12 Thomas S. Zilly United States District Judge 10 13 14 15 16 17 18 19 20 21 22 23 24 25 STIPULATION AND ORDER EXTENDING RESPONSE TO THE COMPLAINT AND INITIAL DISCOVERY DATES - 6 2:18 cv 1132-TSZ
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