National Railroad Passenger Corporation v. Young's Commercial Transfer, Inc. et al.
Filing
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STIPULATION to Continue Disclosure of Rebuttal Experts and Expert Discovery Deadline and ORDER signed by Magistrate Judge Erica P. Grosjean on 11/16/2015. (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
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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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Case No. 1:13-CV-01506-AWI-GSA
(Consolidated with Case No.
1:13-CV-02085-AWI-GSA)
NATIONAL RAILROAD PASSENGER
CORPORATION,
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Plaintiff,
STIPULATION TO CONTINUE
DISCLOSURE OF REBUTTAL EXPERTS
AND EXPERT DISCOVERY
DEADLINE and ORDER
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vs.
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YOUNG'S COMMERCIAL TRANSFER, INC.,
a corporation, and RIGOBERTO FERNANDEZ
JIMENEZ, an individual,
d/b/a JIMENEZ TRUCKING,
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Defendants.
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COMPLAINT FILED: September 17, 2013
CELIA RAMIREZ,
Plaintiff,
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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,
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Defendants.
COMPLAINT FILED: September 18, 2013
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Stipulation to Continue Expert Deadlines 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 have made their initial expert designations with each party designating multiple experts. The
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parties are attempting to arrange a mediation to occur within the next 30 to 45 days and would like
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for that to occur before completing expert discovery and finalizing rebuttal expert disclosure.
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The continuance of the rebuttal expert disclosure, the expert discovery cutoff, and the non-
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dispositive motion filing deadline allow this to be accomplished. This extension of time will not
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affect any other deadlines in the 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 the dates in the Order on Amended Stipulation to Continue Trial Date and
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Discovery Deadlines dated October 26, 2015, be modified only insofar as the Rebuttal Expert
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Disclosure Date, Expert Discovery Cutoff, and Non-dispositive Motion Filing Deadline as follows:
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Rebuttal Expert Disclosure:
January 4, 2015
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Expert Discovery Cutoff:
February 5, 2016
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Non-dispositive Motion Filing Deadline:
February 5, 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: November 10, 2015
REICH LAW FIRM
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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 Expert Deadlines and Order
DATED: November 10, 2015
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LOMBARDI LOPER & CONANT, LLP
By /s/ B. Clyde Hutchinson
Attorneys for Defendants, NATIONAL
RAILROAD PASSENGER CORPORATION
aka AMTRAK, BNSF RAILWAY COMPANY
and BARBARA ANN NEU
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DATED: November 10, 2015
EMERSON · SORENSEN · CHURCH
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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 Expert Deadlines and Order
ORDER
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The Court, having considered the parties’ Stipulation to Continue Discovery Deadlines, and
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good cause appearing therein, orders the scheduling deadlines in this case be modified only insofar
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as the Rebuttal Expert Disclosure Date, Expert Discovery Cutoff, and Non-dispositive Motion
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Filing Deadline as follows:
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Rebuttal Expert Disclosure:
January 4, 2015
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Expert Discovery Cutoff:
February 5, 2016
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Non-dispositive Motion Filing Deadline:
February 5, 2016
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All other deadlines, including the dispositive motion filing deadline, the pre-trial conference,
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and the trial date, remain as set forth in the Court’s Scheduling Order, issued on September 5, 2014
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(ECF No. 28), as amended by the Order on Amended Stipulation to Continue Trial Date and
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Discovery Deadlines, dated October 26, 2015 (ECF No. 43).
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IT IS SO ORDERED.
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Dated:
November 16, 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 Expert Deadlines and Order
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