National Railroad Passenger Corporation v. Young's Commercial Transfer, Inc. et al.
Filing
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STIPULATION to Continue Disclosure of Expert Deadline and ORDER signed by Magistrate Judge Erica P. Grosjean on 10/26/2015. (Martinez, A)
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Jeff Reich—067250
Shane Reich—222948
THE REICH LAW FIRM
304 BANNER COURT, SUITE 2
MODESTO, CA 95356
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209-214-9640
Fax: 925-833-7266
Attorneys for Plaintiff
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA – FRESNO DIVISION
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NATIONAL RAILROAD PASSENGER
CORPORATION,
Plaintiff,
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YOUNG'S COMMERCIAL TRANSFER, INC.,
a corporation, and RIGOBERTO FERNANDEZ
JIMENEZ, an individual,
d/b/a JIMENEZ TRUCKING,
Defendants.
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COMPLAINT FILED: September 17, 2013
CELIA RAMIREZ,
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STIPULATION TO CONTINUE
DISCLOSURE OF EXPERT
DEADLINE and ORDER
vs.
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Case No. 1:13-CV-01506-AWI-GSA
(Consolidated with Case No.
1:13-CV-02085-AWI-GSA)
Plaintiff,
vs.
RIGOBERTO FERNANDEZ JIMENEZ,
JIMENEZ TRUCKING, NATIONAL
RAILROAD PASSENGER CORPORATION,
BARBARA NEU, BNSF RAILWAY
COMPANY, YOUNG'S COMMERCIAL
TRANSFER, INC., and DOES 1 to 200,
Inclusive,
Defendants.
COMPLAINT FILED: September 18, 2013
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Stipulation to Continue Disclosure of Expert Deadline and Proposed Order
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The parties have met and conferred regarding discovery and mediation in this matter. The
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parties are still in the process of finalizing their expert designations and have determined that a one
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week extension on the expert disclosure date will allow for additional examination by the experts
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before completing their reports. The continuance of the expert disclosure date by one week will
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allow this to be accomplished. This extension of time will not affect any other deadlines in the
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case. The parties intend to mediate the Ramirez case.
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IT IS HEREBY STIPULATED by and between the parties hereto, through their respective
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attorneys of record that date in the Order on Amended Stipulation to Continue Trial Date and
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Discovery Deadlines dated October 6, 2015, be modified only insofar as the Expert Disclosure Date
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as follows:
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Expert Disclosure:
October 30, 2015
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Rebuttal Expert Disclosure:
November 13, 2015
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Expert Discovery Cutoff:
January 15, 2016
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Non-dispositive Motion Filing Deadline:
January 22, 2016
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Dispositive Motion Filing Deadline:
February 26, 2016
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Pretrial Conference:
May 26, 2016
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Time: 10:00 a.m.
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Courtroom 2
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Trial:
July 26, 2016
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Time: 8:30 a.m.
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Courtroom 2
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DATED: October 22, 2015
REICH LAW FIRM
By /s/ Shane Reich
Shane Reich
Attorneys for Plaintiff
CELIA RAMIREZ
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The Reich Law Firm
304 BANNER COURT, STE 2
MODESTO, CA 95356
209-214-9640
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Stipulation to Continue Disclosure of Expert Deadline and Order
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DATED: October 22, 2015
LOMBARDI LOPER & CONANT, LLP
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By /s/ Vincent Castillo
Attorneys for Defendants, NATIONAL
RAILROAD PASSENGER CORPORATION
aka AMTRAK, BNSF RAILWAY COMPANY
and BARBARA ANN NEU
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DATED: October 22, 2015
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EMERSON · SORENSEN · CHURCH
By /s/ James D. Emerson
James D. Emerson
Attorneys for Defendants YOUNG'S
COMMERCIAL TRANSFER, INC. and
RIGOBERTO FERNANDEZ JIMENEZ,
individually and dba JIMENEZ TRUCKING
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The Reich Law Firm
304 BANNER COURT, STE 2
MODESTO, CA 95356
209-214-9640
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Stipulation to Continue Disclosure of Expert Deadline and Order
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ORDER
The Court, having considered the parties’ Stipulation to Continue Discovery Deadlines, be
modified by changing only the Expert Disclosure as follows:
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Expert Disclosure:
October 30, 2015
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Rebuttal Expert Disclosure:
November 13, 2015
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Expert Discovery Cutoff:
January 15, 2016
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Non-dispositive Motion Filing Deadline:
January 22, 2016
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Dispositive Motion Filing Deadline:
February 26, 2016
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Pretrial Conference:
May 26, 2016
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Time: 10:00 a.m.
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Courtroom 2
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Trial:
July 26, 2016
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Time: 8:30 a.m.
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All other orders contained in this Court’s Scheduling Order issued on September 5, 2014
(Doc. 28), remain in full force and effect.
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IT IS SO ORDERED.
Dated:
October 26, 2015
/s/
UNITED STATES MAGISTRATE JUDGE
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The Reich Law Firm
304 BANNER COURT, STE 2
MODESTO, CA 95356
209-214-9640
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Stipulation to Continue Disclosure of Expert Deadline and Order
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