Paul C. Buchanan, WSBA No. 24614

Email: pbuchanan@stoel.com

Katherine K. Rosenbaum, WSBA No. 30065

Email: kkrosenbaum@stoel.com

STOEL RIVES LLP

900 SW Fifth Avenue, Suite 2600

Portland, OR 97204-1268

Telephone: (503) 224-3380

Facsimile: (503) 220-2480

Attorneys for Defendant

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF WASHINGTON

DAPHNE LORREN,

Plaintiff,

v.

VANCOUVER CLINIC, INC., P.S.,

Defendant.

Civil No. C06-5023-RBL

STIPULATION AND ORDER

EXTENDING DEADLINE FOR

DISCLOSURE OF EXPERT

TESTIMONY

STIPULATION

1. The parties, by and through their attorneys of record, hereby stipulate to extend

the deadline for disclosure of expert testimony pursuant to Federal Rule of Civil Procedure

(“FRCP”) 26(a)(2) from August 24, 2006 to 30 days after the Court rules on any dispositive

motions or, in the alternative, January 5, 2007, whichever is later.

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DISCLOSURE OF EXPERT TESTIMONY

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2. The extension of time is for good cause based on the parties’ desire to avoid

unnecessary expense and the waste of resources, and to promote judicial economy. The trial in

this matter is scheduled to begin on February 20, 2007. The current deadline for expert

testimony disclosure, August 24, 2006, is considerably more than the default 90 days before trial

provided under FRCP 26(a)(2)(C). The parties agree that the completion of further discovery,

and specifically the depositions currently scheduled for late September and early October in this

matter, and dispositive motions, will enable the parties to assess whether expert testimony is

necessary. The parties also agree that the extension of the expert testimony deadline should not

require any extension of the trial date or other deadlines. The parties have already exchanged

their FRCP 26(a)(1) initial disclosures and documents.

3. Dispositive motions are due no later than November 22, 2006. The parties agree

that postponing any expert testimony disclosures until after the Court has the opportunity to

consider and rule upon any dispositive motions, which may obviate the need for expert

testimony, would further promote judicial economy and avoid unnecessary expense. 

4. Counsel for plaintiff and defendant have conferred, and plaintiff’s counsel

consents to and joins in the requested extension. 

DATED: August 22, 2006.

DOLAN GRIGGS LLP

/s/____________________________

Martin C. Dolan, WSBA No. 36112

Attorney for Plaintiff

STOEL RIVES LLP

/s/________________________________

Paul C. Buchanan, WSBA No. 24614

Katherine K. Rosenbaum WSBA No. 30065

Attorneys for Defendant

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DISCLOSURE OF EXPERT TESTIMONY

Portlnd3-1559984.1 0014757-00005

ORDER

THIS MATTER came before the Court on the foregoing Stipulation of the parties. The

Court has reviewed the parties’ stipulation and, finding that the same is made for good cause, the

Court hereby,

ORDERS that the deadline for disclosure of expert testimony shall be extended from

August 24, 2006 to 30 days after the Court has ruled upon any dispositive motions filed by the

parties or January 5, 2007, whichever is later.

IT IS SO ORDERED this 15th

A

 day of September, 2006.

RONALD B. LEIGHTON

UNITED STATES DISTRICT JUDGE

Presented by:

STOEL RIVES LLP

/s/

Paul C. Buchanan, WSBA No. 24614

Katherine K. Rosenbaum, WSBA No. 30065

Attorneys for Defendant

DOLAN GRIGGS LLP

/s/____________________________________

Martin C. Dolan, WSBA No. 36112

Attorney for Plaintiff

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