Randy's Trucking, Inc. et al v. National Railroad Passenger Corporation et al

Filing 164

STIPULATION to Modify Scheduling Order and Continue Discovery Cut-Off, signed by Judge Oliver W. Wanger on 6/22/2010. (All Discovery Cut-Off presently set for June 18, 2010 is continued until July 15, 2010.) (Gaumnitz, R)

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LOMBARDI, LOPER & CONANT, LLP

B. CLYDE HUTCHINSON, State Bar No. 037526 [e-mail] JASON B. SHANE, State Bar No. 253908 [e-mail] LOMBARDI, LOPER & CONANT, LLP Lake Merritt Plaza 1999 Harrison Street, Suite 2600 Oakland, CA 94612-3541 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant, Counter-Claimant, CrossClaimant and Cross-Defendant NATIONAL RAILROAD PASSENGER CORPORATION, Defendant and Cross-Claimant JOSHUA KYLES, and Defendant and Third-Party Defendant BNSF RAILWAY COMPANY PAUL A. AUCHARD, State Bar No. 60424 [e-mail] AUCHARD & STEWART 2377 West Shaw Avenue, Suite 106 Fresno, CA 93711-3438 Telephone: [phone] Facsimile: [phone] Attorneys for Counter-Claimant BNSF RAILWAY COMPANY UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA ­ FRESNO DIVISION

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Lake Merritt Plaza 1999 Harrison Street, Su i t e 2600 Oakland, CA 94612 - 3 5 4 1

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RANDY'S TRUCKING, INC., and STAR INSURANCE COMPANY, Plaintiffs, v. CITY OF SHAFTER; COUNTY OF KERN; STATE OF CALIFORNIA; CALTRANS; AMTRAK; NATIONAL RAILROAD PASSENGER CORPORATION; BURLINGTON NORTHERN SANTA FE RAILROAD; BNSF RAILWAY COMPANY; and DOES 1 TO 100, Defendants.

Case No. 1:08-cv-00819 0WW DLB STIPULATION TO MODIFY SCHEDULING ORDER AND CONTINUE DISCOVERY CUT-OFF

13249-37030 JBS 585860.1

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Case No. 1:08-cv-00819 0WW DLB

STIPULATION TO MODIFY SCHEDULING ORDER AND CONTINUE DISCOVERY CUT-OFF

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LOMBARDI, LOPER & CONANT, LLP

AND ALL RELATED ACTIONS, CROSS-ACTIONS, AND THIRD PARTY ACTIONS.

IT IS HEREBY STIPULATED by and between all parties, through their designated counsel, that the Court's Scheduling Order be modified and that the "All Discovery Cut-Off," presently set for June 18, 2010, be continued approximately thirty (30) days until July 15, 2010. This extension is based upon the parties' desire to conduct a global mediation prior to incurring the costs associated with expert depositions. The parties have scheduled a mediation with mediator Lee Jacobson for June 24, 2010. Dated: June 17, 2010 ERICKSEN ARBUTHNOT

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Lake Merritt Plaza 1999 Harrison Street, Su i t e 2600 Oakland, CA 94612 - 3 5 4 1

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By:

/s/ Michael D. Ott MICHAEL D. OTT Attorneys for RANDY'S TRUCKING, INC., STAR INSURANCE COMPANY and FERNANDO MANGUIA SANDOVAL

Dated:

June 16, 2010

LOMBARDI, LOPER & CONANT, LLP

By:

/s/ Jason B. Shane JASON B. SHANE Attorneys for NATIONAL RAILROAD PASSENGER CORPORATION, JOSHUA KYLES and BNSF RAILWAY COMPANY

Dated:

June 17, 2010

AUCHARD & STEWART

By:

/s/ Paul Auchard PAUL AUCHARD Attorneys for BNSF RAILWAY COMPANY

13249-37030 JBS 585860.1

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Case No. 1:08-cv-00819 0WW DLB

STIPULATION TO MODIFY SCHEDULING ORDER AND CONTINUE DISCOVERY CUT-OFF

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LOMBARDI, LOPER & CONANT, LLP

Dated:

June 21, 2010

STOLL, NUSSBAUM & POLAKOV, A.P.C.

By:

/s/ Robert J. Stoll, Jr. ROBERT J. STOLL, JR. Attorneys for ROI SMITH

Dated:

June 18, 2010

A.A. ACCIDENT ATTORNEYS, P.L.C.

By:

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Lake Merritt Plaza 1999 Harrison Street, Su i t e 2600 Oakland, CA 94612 - 3 5 4 1

/s/ Paul E. Lee PAUL E. LEE Attorneys for TINA KNOTT

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13249-37030 JBS 585860.1

IT IS SO ORDERED. Dated:

June 22, 2010

/s/ Oliver W. Wanger
UNITED STATES DISTRICT JUDGE
DEAC_Signature-END:

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Case No. 1:08-cv-00819 0WW DLB

STIPULATION TO MODIFY SCHEDULING ORDER AND CONTINUE DISCOVERY CUT-OFF