In Washington, parties file a Motion to Extend Discovery when they need additional time to complete the discovery process. Discovery rules permit gathering relevant information that can lead to admissible evidence. A discovery cutoff date serves two purposes: it prevents the ongoing obligation to produce evidence and guarantees parties sufficient preparation time for trial. The trial court holds the authority to authorize further discovery through different means. Parties can modify or amend the discovery schedule if justice demands it. Before submitting a motion to extend discovery, counsel must engage in a meeting and confer to resolve any discovery disputes. Courts generally receive reviews for their decisions to grant or deny a motion to extend discovery based on whether they have exercised their discretion appropriately.
“The rules of discovery provide that all relevant information likely to lead to admissible evidence is discoverable.” (See Neighborhood Alliance v. County of Spokane (2011) 172 Wash. 2d 702, 717.)
“The purpose of a discovery cutoff date is to protect the parties from a continuing burden of producing evidence and to assure them adequate time to prepare immediately before trial." (See Whittaker Corp. v. Execuair Corp. (1984) 736 F.2d 1341, 1347; Buhr v. Stewart Title of Spokane, LLC, No. 30355-1-III, at *22-23 (Wash. Ct. App. Aug. 1, 2013).)
“In general Washington rules provide for time extensions for good cause shown.” (See Goldendale v. Graves (1976) 14 Wn. App. 925, 929.)
“It is within the trial court's discretion, upon motion, to order further discovery by other means.” (See Hutchinson Cancer Research v. Holman (1987) 107 Wn. 2d 693, 706.)
“A schedule for discovery may be altered or amended whenever justice so requires.” (See Buhr v. Stewart Title of Spokane, LLC, 176 Wash. App. 28, 34 (Wash. Ct. App. 2013).)
“We generally review a trial judge's management of a trial for abuse of discretion.” (See Wash. State Physicians Ins. Exch. Ass'n v. Fisons Corp. (1993) 122 Wn.2d 299, 338, 858 P.2d 1054; Peluso v. Dealerships (2007) 138 Wn. App. 65, 69.)
“An abuse of discretion results when the trial court's decision is manifestly unreasonable or based on untenable grounds or for untenable reasons.” (See Taylor v. Maughan, No. 29911-2-III, at *1 (Wash. Ct. App. Aug. 14, 2012).)
“CR 26(i) requires counsel to meet and confer in an effort to resolve discovery disputes before submitting them to the court. The attorneys must meet and confer either in person or by telephone.” (See Rudolph v. Empirical Research Systems, Inc. (2001) 107 Wash.App. 861, 28 P.3d 813; Dalsing v. Pierce Cnty., Corp. (2015) 357 P.3d 80, 84 n.3.)
“A trial court does not consider a motion to compel until the moving party fulfills the meet-and-confer requirement and files a certification that the conference requirements were met.” (See Collins v. Olympic Interiors Inc., No. 54390-7-II, at *1 (Wash. Ct. App. Apr. 6, 2021).)
It is well settled that, “when responding to discovery, a party cannot simply ignore an interrogatory or request for production. To avoid making an unwanted disclosure, a party must seek a protective order under CR 26(c). An answer that is evasive or misleading is equivalent to a failure to answer.” (See CR 37(d); Magana v. Hyundai Motor Am. (2009) 167 Wn.2d 570, 584, 220 P.3d 191; Guardado v. Guardado (In re Marriage of Guardado) (2018) 2 Wn. App. 2d 1025.)
It is well settled that “the trial court is authorized to impose harsh sanctions, such as a default judgment, for the failure to comply with a discovery order.” (See Rufin v. City of Seattle, No. 76091-2-I, at *1 (Wash. Ct. App. Aug. 21, 2017).)
Sep 13, 2023
Default Judgment
Hon. FAMILY COURT - 2
Pierce County
Pierce County, WA
Out-Of-State Child Custody
Jul 18, 2023
Other
Hon. ANDRE M. PENALVER
Pierce County
Pierce County, WA
Dissolution with Children
Family
Divorce,Separation
Jun 05, 2023
Active
Superior
Clark County, WA
May 24, 2023
Other
Snohomish County
Snohomish County, WA
Apr 04, 2023
Other
Pierce County
Pierce County, WA
Dissolution with Children
Family
Divorce,Separation
Mar 28, 2023
Other
Hon. Angelica Williams
Pierce County
Pierce County, WA
Dissolution with Children
Family
Divorce,Separation
Mar 16, 2023
Other
Spokane County
Spokane County, WA
Mar 14, 2023
Active
Snohomish County
Snohomish County, WA
Mar 09, 2023
Active
Spokane County
Spokane County, WA
Feb 24, 2023
Active
Snohomish County
Snohomish County, WA
Feb 13, 2023
Judgment (Other)
Clark County
Clark County, WA
Feb 10, 2023
Summary Judgment
Pierce County
Pierce County, WA
Jan 06, 2023
Dismissal
Whitman County
Whitman County, WA
Jan 06, 2023
Active
Spokane County
Spokane County, WA
Jan 04, 2023
Dismissal
Clallam County
Clallam County, WA
Jan 03, 2023
Non-Jury Verdict
Pierce County
Pierce County, WA
Injunction
Dec 20, 2022
Active
Benton County
Benton County, WA
Miscellaneous
Dec 12, 2022
Hon. ANDRE M. PENALVER
Pierce County
Pierce County, WA
Dec 09, 2022
Other
Mason County
Mason County, WA
Nov 21, 2022
Closed
Snohomish County
Snohomish County, WA
Nov 16, 2022
Summary Judgment
Spokane County
Spokane County, WA
Miscellaneous
Nov 08, 2022
Dismissal
Pierce County
Pierce County, WA
Nov 01, 2022
Dismissal
Benton County
Benton County, WA
Oct 21, 2022
Dismissal
Kittitas County
Kittitas County, WA
Oct 06, 2022
Other
Pierce County
Pierce County, WA
Dissolution with Children
Family
Divorce,Separation
Sep 01, 2022
Dismissal
Pierce County
Pierce County, WA
Aug 24, 2022
Other
Pierce County
Pierce County, WA
Dissolution with Children
Family
Divorce,Separation
Aug 22, 2022
Active
Mason County
Mason County, WA
Aug 16, 2022
Active
Benton County
Benton County, WA
Aug 15, 2022
Judgment (Other)
Lewis County
Lewis County, WA
Jul 25, 2022
Active
Spokane County
Spokane County, WA
Jul 19, 2022
Closed
Spokane County
Spokane County, WA
Jul 07, 2022
Dismissal
Pierce County
Pierce County, WA
Jul 01, 2022
Judgment (Other)
Snohomish County
Snohomish County, WA
Jun 30, 2022
Trial Verdict
Pierce County
Pierce County, WA
Jun 30, 2022
Other
Pierce County
Pierce County, WA
Dissolution with Children
Family
Divorce,Separation
Jun 21, 2022
Default Judgment
Pierce County
Pierce County, WA
Commercial
Commercial
General Commercial
Jun 15, 2022
Other
Snohomish County
Snohomish County, WA
Jun 01, 2022
Active
Spokane County
Spokane County, WA
Jun 01, 2022
Dismissal
Thurston County
Thurston County, WA
May 26, 2022
Active
Kitsap County
Kitsap County, WA
May 24, 2022
Active
San Juan County
San Juan County, WA
May 24, 2022
Active
Thurston County
Thurston County, WA
May 23, 2022
Other
Mason County
Mason County, WA
May 16, 2022
Active
Clark County
Clark County, WA
May 04, 2022
Dismissal
Spokane County
Spokane County, WA
Apr 29, 2022
Consolidation
Hon. Shelly K Speir-Moss
Pierce County
Pierce County, WA
Trust/Est. Dispute Resolution
Probate
Trusts
Trust/Est. Dispute Resolution
Probate
Trusts
Apr 11, 2022
Closed
Thurston County
Thurston County, WA
Apr 06, 2022
Closed
Spokane County
Spokane County, WA
Apr 06, 2022
Hon. FAMILY COURT - 2
Pierce County
Pierce County, WA
Relative Child Visitation
Family
Custody,Visitation
Apr 05, 2022
Active
Thurston County
Thurston County, WA
Apr 01, 2022
Dismissal
Clark County
Clark County, WA
Mar 31, 2022
Hon. FAMILY COURT - 2
Pierce County
Pierce County, WA
Mar 30, 2022
Consolidation
Spokane County
Spokane County, WA
Mar 28, 2022
Dismissal
Pierce County
Pierce County, WA
Mar 18, 2022
Dismissal
Chelan County
Chelan County, WA
Mar 11, 2022
Judgment (Other)
Thurston County
Thurston County, WA
Mar 10, 2022
Summary Judgment
Pierce County
Pierce County, WA
Feb 28, 2022
Closed
Spokane County
Spokane County, WA
Legal Separation with Children
Family
Divorce,Separation
Feb 23, 2022
Active
Spokane County
Spokane County, WA
Feb 22, 2022
Other
Clark County
Clark County, WA
Feb 02, 2022
Dismissal
Spokane County
Spokane County, WA
Feb 01, 2022
Dismissal
Chelan County
Chelan County, WA
Jan 31, 2022
Dismissal
Yakima County
Yakima County, WA
Jan 31, 2022
Other
Thurston County
Thurston County, WA
Jan 24, 2022
Dismissal
Okanogan County
Okanogan County, WA
Jan 21, 2022
Settlement
Pierce County
Pierce County, WA
Dissolution with Children
Family
Divorce,Separation
Jan 19, 2022
Active
Benton County
Benton County, WA
Jan 19, 2022
Dismissal
Whatcom County
Whatcom County, WA
Jan 18, 2022
Default Judgment
Pierce County
Pierce County, WA
Commercial
Commercial
General Commercial
Jan 11, 2022
Dismissal
Whatcom County
Whatcom County, WA
Jan 10, 2022
Other
Hon. FAMILY COURT - 1
Pierce County
Pierce County, WA
Parenting Plan\Child Support
Family
Child Support
Jan 07, 2022
Dismissal
Kitsap County
Kitsap County, WA
Jan 06, 2022
Closed
Mason County
Mason County, WA
Jan 06, 2022
Dismissal
Skagit County
Skagit County, WA
Jan 05, 2022
Other
Hon. Trial Date
King County
King County, WA
Parenting Plan / Child Support
Family
Child Support
Jan 04, 2022
Dismissal
Thurston County
Thurston County, WA
Jan 04, 2022
Dismissal
Spokane County
Spokane County, WA
Jan 03, 2022
Other
Hon. Judge Whedbee
King County
King County, WA
Parenting Plan / Child Support
Family
Child Support
Jan 03, 2022
Other
Hon. Judge Rosen
King County
King County, WA
Parenting Plan / Child Support
Family
Child Support
Jan 03, 2022
Relief Denied
King County
King County, WA
Parenting Plan / Child Support
Family
Child Support
Jan 03, 2022
Other
Pierce County
Pierce County, WA
Dissolution with Children
Family
Divorce,Separation
Dec 30, 2021
Active
Snohomish County
Snohomish County, WA
Dec 29, 2021
Dismissal
Thurston County
Thurston County, WA
Dec 28, 2021
Active
Spokane County
Spokane County, WA
Dec 14, 2021
Non-Jury Verdict
Whatcom County
Whatcom County, WA
Dec 10, 2021
Active
Yakima County
Yakima County, WA
Dec 07, 2021
Judgment (Other)
Clark County
Clark County, WA
Dec 07, 2021
Summary Judgment
Pierce County
Pierce County, WA
Commercial
Commercial
General Commercial
Nov 29, 2021
Pierce County
Pierce County, WA
Domestic Violence Protection
Family
Domestic Violence
Nov 19, 2021
Stipulated Judgment
Spokane County
Spokane County, WA
Nov 19, 2021
Trial Verdict
Spokane County
Spokane County, WA
Nov 16, 2021
Dismissal
Pierce County
Pierce County, WA
Nov 15, 2021
Other
Clark County
Clark County, WA
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