National Railroad Passenger Corporation v. Young's Commercial Transfer, Inc. et al.

Filing 44

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: [phone]

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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