Washington Cases September 19, 2022: Krabach v. King Cnty.

Case Description

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Cristina Sepe, WSBA #53609

Karl D. Smith, WSBA #41998

Deputy Solicitors General ATTORNEY GENERAL OF WASHINGTON

Robert A. Bouvatte, Jr., WSBA #50220 ROBERT A. BOUVATTE, PLLC

Attorneys for Defendants Jay Inslee and Steve Hobbs

David J. Hackett, WSBA #21236

Ann Summers, WSBA #21509 Senior Deputy Prosecuting Attorneys

KING COUNTY PROSECUTING ATTORNEY'S OFFICE

Attorneys for Defendants King County and Director Wise

STIPULATED MOTION AND ORDER REGARDING BRIEFING SCHEDULE ON MOTION FOR PRELIMINARY INJUNCTION

BARBARA JACOBS ROTHSTEIN U.S. DISTRICT COURT JUDGE

I. MOTION

Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure, and Local Civil Rules 7(d)(1) and 10(g), and the Court's Standing Order [D.E. 7], the parties to the above-captioned case, including the Plaintiff, AMBER KRABACH (“Plaintiff”); JAY INSLEE, in his official capacity as Governor of the State of Washington (“Governor Inslee”); STEVE HOBBS, in his official capacity as Secretary of State of the State of Washington (“Secretary Hobbs”); KING COUNTY (the “County”); and JULIE WISE, in her individual capacity and official capacity as

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Director of King County Elections (“Director Wise”) (collectively, the “Defendants”); by and through their undersigned attorneys, have stipulated to and hereby jointly request the Court's approval of a shortened briefing schedule upon the Plaintiff's Motion for Preliminary Injunction (the “Motion”) [D.E. 12], and in support thereof, further state as follows:

1. Plaintiff's Complaint [D.E. 1] was filed on September 7, 2022.

2. On September 13, 2022, the Court issued its Standing Order for All Civil Cases (the “Standing Order”) [D.E. 7], which establishes a briefing schedule on Plaintiff's Motion [D.E. 12] different from that established by the Local Rules.

3. The Standing Order [D.E. 7] establishes a deadline of October 7, 2022, for Defendants' opposition to Plaintiff's Motion [D.E. 12]. Under that briefing schedule Plaintiff's reply would be due October 21, 2022.

4. In the Motion [D.E. 12], however, Plaintiff has respectfully requested that the Court issue a decision on her request for preliminary injunctive relief prior to October 20, 2022, because Plaintiff believes that she faces irreparable harm, for the reasons set forth in the Motion [D.E. 12], if preliminary injunctive relief is not entered at that time.

5. The undersigned counsel for the parties have conferred as to this issue, in the course of conferring with respect to the Motion [D.E. 12], and have agreed upon a shortened briefing upon Plaintiff's Motion [D.E. 12], such that same can be fully-briefed prior to October 20, 2022.

6. The Parties stipulate to and request entry of the following briefing schedule for Plaintiff's Motion for Preliminary Injunction [D.E. 12]:

i. Plaintiff's Motion [D.E. 12] was filed and served on all parties as of September 16, 2022.

ii. Defendants' oppositions to the Motion [D.E. 12] shall be filed and served not later than October 4, 2022;

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iii. Plaintiff's Reply in support of the Motion [D.E. 12], if any, shall be filed and served not later than October 14, 2022.

II. STIPULATION

IT IS HEREBY STIPULATED by the parties, through their undersigned counsel, that this Court should enter an order providing that:

1. The following briefing and hearing schedule shall govern resolution of the Plaintiff's Motion for Preliminary Injunction [D.E. 12] in this case:

DATE	EVENT
September 16, 2022	Plaintiff's Motion [D.E. 12] was filed and served.
October 4, 2022	Defendants' oppositions to Plaintiff's Motion [D.E. 12] shall be filed and served.
October 14, 2022	Plaintiff's Reply in Support of the Motion [D.E. 12], if any, shall be filed and served.

2. Except as amended via this stipulation, all other applicable rules and scheduling orders issued in this case shall remain in full force and effect.

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It is SO AGREED.

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ORDER

Having reviewed the foregoing stipulated motion and good cause appearing therefore, IT IS HEREBY ORDERED:

1. The following briefing and hearing schedule shall govern resolution of Plaintiff's Motion for Preliminary Injunction in this case:

DATE	EVENT
September 16, 2022	Plaintiff's Motion [D.E. 12] was filed and served.
October 4, 2022	Defendants' oppositions to Plaintiff's Motion [D.E. 12] shall be filed and served.
October 14, 2022	Plaintiff's Reply in Support of the Motion [D.E. 12], if any, shall be filed and served.

2. Except as amended via this stipulation, all other scheduling Orders issued in this case shall remain in full force and effect.

IT IS SO ORDERED.