Case: Escobar v. Baker

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF (Summons(es) issued in blank) Receipt # 194413 (dktclk) (Entered: 01/27/1992)

ORDER/NOTICE OF JOINT STATUS REPORT Joint Status Report due 5/8/92 (cc: all counsel) (dktclk) (Entered: 02/07/1992)

REPRESENTATION BY WA LOCAL CNSL-Douglas P. Wyckoff regarding application for permission of Paul R. J. Connolly to participate as co-cnsl for dfts. (dktclk) (Entered: 02/25/1992)

ANSWER to complaint [1-1] by defendant Anne Baker, defendant Jerry Dobbins (dktclk) (Entered: 02/25/1992)

APPLICATION FOR ADMISSION to practice of Paul R.J. Connolly on behalf of Anne Baker, Jerry Dobbins (dktclk) (Entered: 02/28/1992)

MINUTE ORDER: by Judge Thomas S. Zilly APPROVING application [5-1] of Paul R. J. Connolly to appear as counsel for Anne Baker & Jerry Dobbins (cc: all counsel) (dktclk) (Entered: 02/28/1992)

NOTICE by defendant Anne Baker, defendant Jerry Dobbins of taking depo of Arthur E. Schmidt on 3/25/92 @ 9:00am (dktclk) (Entered: 03/04/1992)

AFFIDAVIT OF SERVICE of Interrogatories & request for production of documents. served on 2/27/92 upon Evergreen Legal Services, Snohomish Cty Office. (dktclk) (Entered: 03/04/1992)

RETURN of SERVICE of subps served upon Arthur E. Schmidt et al on 3/13/92. (dktclk) (Entered: 03/20/1992)

JOINT STATUS REPORT filed by all parties. Est. Trial Days: 5 (dktclk) (Entered: 05/13/1992)

ANSWER to complaint [1-1] by defendant Apolinar Soto (dktclk) (Entered: 05/13/1992)

RETURN of SERVICE of Answer of Dft Soto served upon Rebecca Smith on 5/6/92 (dktclk) (Entered: 05/13/1992)

PROPOSED STIPULATED PROTECTIVE ORDER (dktclk) (Entered: 05/26/1992)

STIPULATED PROTECTIVE ORDER by Judge Thomas S. Zilly. Refer to document for details. (cc: all counsel) (dktclk) (Entered: 06/04/1992)

PRE-TRIAL SCHEDULING ORDER/NOTICE by Judge Thomas S. Zilly Discovery cutoff 12/24/92 Motion filing deadline 1/28/93 Pretrial order to be submitted by 3/9/93 Pretrial conference set for 3:30 3/12/93 Trial set for 3/29/93 Trial briefs to be submitted by 3/24/93. Deadline for joining additional parties 9/4/92 (cc: all counsel) (dktclk) (Entered: 06/10/1992)

ORDER by Judge Thomas S. Zilly ; 39.1 designation set for 12/24/92 (cc: all counsel) (dktclk) (Entered: 06/10/1992)

RETURN of SERVICE of subp served upon Paolino Garcia on 7/13/92 (dktclk) (Entered: 07/29/1992)

LETTER to Judge Zilly from Rebecca Smith and Paul Connolly re: request for extension of settlement conference (dktclk) (Entered: 07/29/1992)

MINUTE ORDER: by Judge Thomas S. Zilly. The Ct having considered cnsl's joint request for an extension of settlement conference time hereby EXTENDS the time in which the parties must hold a settlement conference until 9/30/92 (cc: all counsel) (dktclk) (Entered: 07/29/1992)

STATEMENT by plaintiffs of material facts that are not in dispute (dktclk) (Entered: 09/17/1992)

MOTION by plaintiff to withdraw attorney Rebecca Ann Smith from representing Andres Reyes Barbosa, Dario Escobar and Filiberto Mejia Sandoval noted for 10/2/92 (dktclk) (Entered: 09/17/1992)

DECLARATION of Rebecca Smith re motion to withdraw attorney Rebecca Ann Smith from representing Andres Reyes Barbosa, Dario Escobar and Filiberto Mejia Sandoval [20-1] (dktclk) (Entered: 09/17/1992)

MOTION by plaintiff for partial summary judgment noted for 10/9/92. ORAL ARGUMENT REQUESTED (dktclk) (Entered: 09/17/1992)

MEMORANDUM by plaintiff in support of motion for partial summary judgment [23-1]. Exhibits attached. Document in expandable folder (dktclk) (Entered: 09/17/1992)

RETURN of SERVICE of Plas' mtn for partial sum jgm etc served upon Paul Connolly on 9/16/92 (dktclk) (Entered: 09/17/1992)

LODGED ORDER: re: motion for partial summary judgment (dktclk) (Entered: 09/17/1992)

MOTION by defendant to compel attendance of Plas at depo in forum state ORAL ARGUMENT BY TELECOMMUNICATION REQUESTED (dktclk) (Entered: 09/21/1992)

MEMORANDUM by defendant in support of motion to compel attendance of Plas at depo in forum state [26-1] (dktclk) (Entered: 09/21/1992)

AFFIDAVIT of Paul R.J. Connolly in support of motion to compel attendance of Plas at depo in forum state [26-1]. Exhibit A attached (dktclk) (Entered: 09/21/1992)

MOTION by defendant to compel answers to interrogatories and production of documents ORAL ARGUMENT BY TELECOMMUNICATION REQUESTED (dktclk) (Entered: 09/21/1992)

MEMORANDUM by defendant in support of motion to compel answers to interrogatories and production of documents [29-1] (dktclk) (Entered: 09/21/1992)

AFFIDAVIT of Paul R.J. Connolly in support of motion to compel answers to interrogatories and production of documents [29-1] Exhibits A-C attached. (dktclk) (Entered: 09/21/1992)

RETURN of SERVICE of Dfts' mtn to compel etc served upon Rebecca Smith on 9/18/92 (dktclk) (Entered: 09/21/1992)

LODGED ORDER: re: motion to compel attendance of Plas at depo in forum state (dktclk) (Entered: 09/21/1992)

LODGED ORDER: re: motion to compel answers to interrogatories and production of documents (dktclk) (Entered: 09/21/1992)

PROPOSED STIPULATION AND ORDER TO AMEND COMPLAINT (dktclk) (Entered: 09/24/1992)

PROPOSED FIRST AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF (dktclk) (Entered: 09/24/1992)

STIPULATION and ORDER TO AMEND COMPLAINT by Judge Thomas S. Zilly. (cc: all counsel) (dktclk) (Entered: 09/29/1992)

AMENDED COMPLAINT [1-1] by plaintiff; terminating Apolinar Soto; adding Hipolito Soto (dktclk) (Entered: 09/29/1992)

RESPONSE(Memorandum in Opposition) by plaintiff to motion to compel answers to interrogatories and production of documents [29-1], motion to compel attendance of Plas at depo in forum state [26-1]. Exhibits attached. (dktclk) (Entered: 10/02/1992)

DECLARATION of Gabriel Alarcon. NOTE: NO SIGNATURE (dktclk) (Entered: 10/02/1992)

DECLARATION of Jose Barajas. NOTE: NO SIGNATURE (dktclk) (Entered: 10/02/1992)

DECLARATION of Cesar Perez Lopez. NOTE NO SIGNATURE (dktclk) (Entered: 10/02/1992)

DECLARATION of Samuel Romero. NOTE: NO SIGNATURE (dktclk) (Entered: 10/02/1992)

DECLARATION of Crisogono Sanchez. NOTE: NO SIGNATURE (dktclk) (Entered: 10/02/1992)

DECLARATION of Idilio Flores Quintana. NOTE NO SIGNATURE (dktclk) (Entered: 10/02/1992)

RETURN of SERVICE of Plas memorandum in opposition of Dfts' mtn to compel w/ exhibits etc served upon Paul Connolly on 9/28/92 (dktclk) (Entered: 10/02/1992)

DECLARATION of Rebecca Smith in response to motion to compel answers to interrogatories and production of documents [29-1] (dktclk) (Entered: 10/05/1992)

RETURN of SERVICE of declaration of Rebecca Smith etc served upon Paul Connolly on 9/30/92 (dktclk) (Entered: 10/05/1992)

MINUTE ORDER: by Judge Thomas S. Zilly. Per stipulation of the parties Pla's mtn for partial sum jgm is RENOTED to 10/16/92 (cc: all counsel) (dktclk) (Entered: 10/06/1992)

MINUTE ORDER: by Judge Thomas S. Zilly granting motion to withdraw attorney Rebecca Ann Smith from representing Andres Reyes Barbosa, Dario Escobar and Filiberto Mejia Sandoval [20-1] (cc: all counsel) (dktclk) (Entered: 10/08/1992)

REPLY by defendant TO RESPONSE to motion to compel attendance of Plas at depo in forum state [26-1] (dktclk) (Entered: 10/13/1992)

RETURN of SERVICE of Dft's reply to response to mtn to compel served upon Rebecca Smith on 10/7/92 (dktclk) (Entered: 10/13/1992)

MINUTES: TSZ; Dep Clerk: CC; CR: MARCIA FERRELL; TELEPHONE STATUS CONFERENCE. Attys present: Rebecca Smith & Paul Connolly. Ct GRANTS mtn to compel answers. Ct GRANTS in part and DENIES in part the mtn to compel attendance at depos. Refer to minutes for details. (cc: all counsel) (dktclk) (Entered: 10/16/1992)

ORDER TO COMPEL ANSWERS TO INTERROGATORIES AND PRODUCTION OF DOCUMENTS FROM DARIO ESCOBAR, ET AL by Judge Thomas S. Zilly. Refer to order for details. (cc: all counsel) (dktclk) (Entered: 10/16/1992)

CROSS MOTION by defendant Anne Baker, defendant Jerry Dobbins for summary judgment. ORAL ARGUMENT REQUESTED noted for 11/13/92 AND OPPOSITION to Plas' mtn for partial sum jgm (dktclk) (Entered: 10/20/1992)

MEMORANDUM by defendant Anne Baker, defendant Jerry Dobbins in support of motion for summary judgment. ORAL ARGUMENT REQUESTED [51-1] AND opposition to Plas' mtn for partial sum jgm (dktclk) (Entered: 10/20/1992)

STATEMENT of undisputed facts by defendant Anne Baker, defendant Jerry Dobbins in support of motion for summary judgment. ORAL ARGUMENT REQUESTED [51-1] (dktclk) (Entered: 10/20/1992)

AFFIDAVIT of Anne Baker (dktclk) (Entered: 10/20/1992)

AFFIDAVIT of Jerry Dobbins (dktclk) (Entered: 10/20/1992)

AFFIDAVIT of Karen Nelson. Exhibits attached (dktclk) (Entered: 10/20/1992)

AFFIDAVIT of Hipolito Soto (dktclk) (Entered: 10/20/1992)

AFFIDAVIT of Paul R.J. Connolly. Exhibits attached. (dktclk) (Entered: 10/20/1992)

RETURN of SERVICE of Dfts' cross mtn for sum jgm etc served upon Rebecca Smith on 10/17/92 (dktclk) (Entered: 10/20/1992)

LODGED ORDER: re: motion for summary judgment. ORAL ARGUMENT REQUESTED (dktclk) (Entered: 10/20/1992)

MINUTE ORDER: by Judge Thomas S. Zilly. The Clerk is directed to RENOTE Plas' mtn for partial sum jgm to 10/23/92 (cc: all counsel) (dktclk) (Entered: 10/20/1992)

MINUTE ORDER: by Judge Thomas S. Zilly. The Clerk is directed to RENOTE Plas' mtn for partial sum jgm to 11/13/92 (cc: all counsel) (dktclk) (Entered: 10/26/1992)

DECLARATION of Carlos Mariscal (dktclk) (Entered: 10/27/1992)

DECLARATION of Jose Barajas (dktclk) (Entered: 10/27/1992)

DECLARATION of Idilio Flores Quintana (dktclk) (Entered: 10/27/1992)

DECLARATION of Samuel Romero (dktclk) (Entered: 10/27/1992)

DECLARATION of Gabriel Alarcon (dktclk) (Entered: 10/27/1992)

DECLARATION of Crisogono Sanchez (dktclk) (Entered: 10/27/1992)

REPLY by plaintiff TO RESPONSE to motion for partial summary judgment [23-1]. Exhibits attached. Document in expandable folder (dktclk) (Entered: 11/12/1992)

RETURN of SERVICE of Plas' reply brief in support of mtn for partial sum jgm etc served upon Paul Connolly on 11/6/92 (dktclk) (Entered: 11/12/1992)

PROPOSED PLAS' MTN AND ORDER TO FILE AN OVER LENGTH BRIEF (dktclk) (Entered: 11/12/1992)

PROPOSED PLAS' MEMORANDUM IN OPPOSITION TO DFTS' MTN FOR SUM JGM (dktclk) (Entered: 11/12/1992)

NOTICE by Tanya Cook re: depo of Anne Baker, Jerry Dobbins & Karen Nelson transcribed and sealed and served upon Rebecca Smith on 5/14/92 (dktclk) (Entered: 11/18/1992)

ORDER by Judge Thomas S. Zilly. It is ordered that Plas shall be allowed to file their brief which exceeds the 24 page limit (cc: all counsel) (dktclk) (Entered: 11/18/1992)

RESPONSE(Memorandum in Opposition) by plaintiff to motion for summary judgment. ORAL ARGUMENT REQUESTED [51-1]. Exhibits attached (dktclk) (Entered: 11/18/1992)

SUBSTITUTION OF COUNSEL Darrel Peeples on behalf of Anne Baker, Jerry Dobbins, Hipolito Soto & terminating attorney Douglas Peter Wyckoff (dktclk) (Entered: 11/23/1992)

DECLARATION of Idilio Flores Quintana (dktclk) (Entered: 11/23/1992)

RETURN of SERVICE of declaration of Idilio Flores Quintana served upon Paul Connolly. Note not dated or signed (dktclk) (Entered: 11/23/1992)

REPLY by defendant TO RESPONSE to motion for summary judgment. ORAL ARGUMENT REQUESTED [51-1] (dktclk) (Entered: 11/24/1992) REQUESTED noted for 1/15/93. Cld cnsl re: proper noting of mtn (dktclk) (Entered: 12/31/1992)

MEMORANDUM by defendant in support of motion to extend discovery cut- off date. ORAL ARGUMENT REQUESTED [77-1] Exhibits attached (dktclk) (Entered: 12/31/1992)

RETURN of SERVICE of Dfts' mtn to extend discovery etc served upon Rebecca Smith on 12/28/92 (dktclk) (Entered: 12/31/1992)

MINUTE ORDER: by Judge Thomas S. Zilly. The Ct DENIES IN PART AND DEFERS IN PART DFTS' MTN FOR SUM JGM. Refer to order for details. The Ct DEFERS ruling on the issues raised in Plas' mtn for partial sum jgm until oral argument. The Ct SCHEDULES ORAL ARGUMENT ON ALL DEFERRED issues for 1/22/93 at 3:00 p.m. The mtns shall be renoted to 1/22/93 (cc: all counsel) (dktclk) (Entered: 01/05/1993)

SELECTION OF William Bender as 39.1 mediator (cc: all counsel) (dktclk) (Entered: 01/07/1993)

LETTER from defendants to strike motion to extend discovery cut off (dktclk) (Entered: 01/14/1993)

MOTION by defendant to dismiss all claims of Plas Gabriel Alarcon and Crisogono Sanchez noted for 2/12/93. Exhibits attached (dktclk) (Entered: 01/22/1993)

DECLARATION of De Idilio Flores Quintana (dktclk) (Entered: 01/22/1993)

DECLARATION of Crisogono Soto (dktclk) (Entered: 01/22/1993)

DECLARATION of De Cesar Perez (dktclk) (Entered: 01/22/1993)

DECLARATION of De Esteban Cedillo Sanchez (dktclk) (Entered: 01/22/1993)

AFFIDAVIT of Paul R.J. Connolly pursuant to FRCP 56(f). Exhibits attached (dktclk) (Entered: 01/29/1993)

RETURN of SERVICE of afdt of Paul R.J. Connolly served upon Rebecca Smith on 1/22/93 (dktclk) (Entered: 01/29/1993)

MINUTE ORDER: by Judge Thomas S. Zilly. The Ct RESCHEDULES oral argument on the parties' cross-mtns for sum jgm for 2/5/93 at 3:30 p.m. In-court hrg set for 3:30 2/5/93 (cc: all counsel) (dktclk) (Entered: 01/29/1993)

DECLARATION of Rebecca Smith in response to motion to dismiss all claims of Plas Gabriel Alarcon and Crisogono Sanchez [83-1] (dktclk) (Entered: 02/01/1993)

DECLARATION of Rebecca Smith (dktclk) (Entered: 02/01/1993)

RETURN of SERVICE of Pla's declaration in response to mtn to dismiss etc served upon Paul Connolly on 1/28/93 (dktclk) (Entered: 02/01/1993)