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No. 198 MOTION to Stay Bill of Costs, filed by Plaintiffs Marli Brown, Lacey Smith

Document Brown et al v. Alaska Airlines Inc et al, 2:22-cv-00668, No. 198 (W.D.Wash. Jun. 27, 2024)

Motion to Stay

efficient and expedient resolution of cases”); Clinton v. Jones, 520 U.S. 681, 706 (1997) (“The District Court has broad discretion to stay proceedings as an incident to its power to control its own docket.”); Mayes v. Int’l Markets Live, No. 2:22-CV-01269-TL, 2023 WL 6196951, at *1 (W.D.

Under Federal Rule of Civil Procedure 54(d)(1), “the decision whether to award costs ultimately lies within the sound discretion of the district court.” Marx v. Gen. Revenue Corp., 568 U.S. 371, 377 (2013).

This is “not an exhaustive list of good reasons for declining to award costs, but rather a starting point for analysis.” Escriba, 743 F.3d at 1248 (internal quotation marks omitted).

“[A] public interest [is] at stake because the case involves a civil rights issue and analogous litigation could be chilled if costs are taxed.” Newman v. Underhill, No. 5:23-CV-00033-SP, 2024 WL 1647218, at *2 (C.D.

On June 14, 2024, I emailed counsel of record for Defendants to ask whether they would agree to stay the briefing and consideration of the motions for costs and any objections until after the appeal concludes, in the interest of efficiency for the Court and the parties.

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No. 72 AMENDED ORDER Setting Trial Dates and Related Dates

Document Brown et al v. Alaska Airlines Inc et al, 2:22-cv-00668, No. 72 (W.D.Wash. Jan. 17, 2023)

Pursuant to the Federal Rules of Civil Procedure and the Local Civil Rules of this Court, and based on Plaintiﬀs’ Unopposed Motion to Amend Scheduling Order, the Court amends the Order Setting Trial Dates and Related dates in this case as detailed below:

Reports from expert witness under FRCP 26(a)(2) due Discovery completed by March 6, 2024 August 10, 2023 All dispositive motions must be filed by All motions in limine must be filed by Joint Pretrial Statement Pretrial conference September 10, 2023

October 9, 2023 February 2, 2024 February 12, 2024 February 23, 2024 7-10 days Length of Jury Trial

Order -Plaintiffs’ Unopposed Motion to Amend Scheduling Order (No. 2-22-CV-668-BJR) Ard Law Group PLLC P.O.

DATED this 17th day of January, 2023.

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No. 190 MOTION FOR BILL OF COSTS , filed by Defendant Association of Flight Attendants-CWA AFL-CIO

Document Brown et al v. Alaska Airlines Inc et al, 2:22-cv-00668, No. 190 (W.D.Wash. Jun. 12, 2024)

Motion for Costs

Under the Federal Rules of Civil Procedure, the prevailing party should generally recover costs.

“Unless a federal statue, these rules, or a court order provides otherwise, costs – other than attorney’s fees – should be allowed to the prevailing party.” Fed. R. Civ.

Accordingly, AFA is a prevailing party in this case and entitled to recover costs to the extent permitted by the federal and local civil rules.

Costs for obtaining videotaped recording and written transcripts of depositions are both taxable under 28 U.S.C. § 1920.

1 Invoices documenting these costs are attached as Exhibit 1 to the Declaration of Ben Berger, accompanying this Motion.

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No. 188 MOTION FOR BILL OF COSTS , filed by Defendant Alaska Airlines Inc

Document Brown et al v. Alaska Airlines Inc et al, 2:22-cv-00668, No. 188 (W.D.Wash. Jun. 12, 2024)

Motion for Costs

MARLI BROWN and LACEY SMITH, Case No. 2:22-cv-00668-BJR Plaintiffs,

Pursuant to 28 U.S.C. § 1920, Rule 54(d) of the Federal Rules of Civil Procedure, and Local Civil Rule 54(d), Defendant Alaska Airlines, Inc. (“Alaska”) submits this Bill of Costs in connection with this Court’s May 22, 2024 entry of judgment against Plaintiffs Marli Brown and Lacey Smith (“Plaintiffs”), Docket No. 187.

Alaska is entitled to recover costs in this matter because it is the prevailing parties because Alaska won summary judgment on all claims brought by Plaintiffs.

The basis for the total amount sought is discussed below and detailed further in the Court’s Bill of Costs form and the necessary exhibits, which are attached hereto.

All of the depositions taken in this case were necessary, as they were either relied upon by the parties in briefing the Alaska’s Motion for Summary Judgment or taken at Plaintiffs’ request.

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No. 185 MOTION Strike Alaska's Notice of Supplemental Authority re 184 Notice of Supplemental Authority ...

Document Brown et al v. Alaska Airlines Inc et al, 2:22-cv-00668, No. 185 (W.D.Wash. May. 9, 2024)

Motion to Strike

... OF SUPPLEMENTAL AUTHORITY Ard Law Group PLLC P.O. Box 11633 Bainbridge Island, WA 98110 (206) 701-9243 Case 2:22-cv-00668-BJR Document 185 Filed 05/09/24 Page 2 of 2 1 2 3 4 5 6 7 8 9 be stricken and that none ...

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No. 57 ORDER granting Defendant's 44 Motion to Dismiss

Document Brown et al v. Alaska Airlines Inc et al, 2:22-cv-00668, No. 57 (W.D.Wash. Nov. 23, 2022)

Motion to Dismiss (Demurrer)Granted

Giving people blanket permission to enter private spaces for the opposite sex enables sexual predators to exploit the rules and gain easy access to victims.

A. Motion to Dismiss Standard The allegations in a complaint must “contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Twombly, 550 U.S. at 570).

3 The Supreme Court has also “recognized on numerous occasions that ‘[t]he duty of fair representation is ... implicit in the National Labor Relations Act.’” United Parcel Serv., Inc. v. Mitchell, 451 U.S. 56, 67 (1981) (citing Electrical Workers v. Foust, 442 U.S. 42, 46, n. 8).

The duty “applies to all representational activity in which the union engages, including the ‘negotiation, administration, and enforcement of collective bargaining agreements.’” Madison v. Motion Picture Set Painters & Sign Writers Loc.

“To determine whether [a plaintiff’s] state law claims assert rights separate from those secured by the federal duty of fair representation, the court must look to the conduct at the heart of the controversy.” Madison, 132 F. Supp.

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