Clymore, et al v. Federal Railroad Administration et al

Filing 39

STIPULATION and ORDER GRANTING the parties' request for a continuance of pretrial dates as follows: Non-Expert Discovery due by 10/30/2015; Expert Discovery due by 4/1/2016; Designation of Expert Witnesses due by 11/20/2015; Supplemental Designation of Expert Witnesses due by 12/18/2015; Non-Dispositive Motions filed by 12/4/2015; and Dispositive Motions filed by 4/8/2016. Order signed by Magistrate Judge Sandra M. Snyder on 8/20/2015. (Rooney, M)

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BENJAMIN B. WAGNER
United States Attorney
JEFFREY J. LODGE
Assistant United States Attorney
2500 Tulare Street, Suite 4401
Fresno, California 93721
Telephone: [phone]
Facsimile: [phone]

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Attorneys for the United States

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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RICHARD CLYMORE, an individual; DEBRA )
HARBIN-CLYMORE, an individual,
)
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Plaintiffs,
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v.
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FEDERAL RAILROAD ADMINISTRATION, )
a Federal Public Entity; CHARLES MARK
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HAGOOD, an individual; and DOES 1 through )
10, Inclusive,
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Defendants.
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)

Case No. 1:14-cv-00101 AWI/SMS

STIPULATION EXTENDING
SCHUDULING DEADLINES;
ORDER

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Plaintiffs, Richard Clymore and Debra Harbin-Clymore (“Plaintiffs”), and Defendant United

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States (“Defendant”), by and through their undersigned counsel, jointly stipulate by and through the

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undersigned counsel, to continue the following deadlines in this action as more specifically set forth

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below.

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The parties base this stipulation on good cause as the parties have agreed to participate in a

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mediation to resolve the matter. The parties anticipate the mediation be held the first part of October,

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2015. However, if the mediation is unsuccessful, the parties require this brief extension of

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approximately six weeks, to complete discovery in the case. Due to the number of depositions to be

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taken as well as the location of those depositions, the non-expert discovery date currently set cannot

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be met. The parties agree to extend certain scheduling deadlines without affecting the pre-trial

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conference or trial date in this action.

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STIPULATION EXTENDING SCHEDULING DEADLINES; [PROPOSED] ORDER

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Old Date

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New Date

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Non-Expert Discovery Cutoff:

September 18, 2015

October 30, 2015

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Expert Disclosure:

October 9, 2015

November 20, 2015

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Supplemental Expert Disclosures:

November 6, 2015

December 18, 2015

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Expert Discovery Cut-Off:

February 19, 2016

April 1, 2016

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Non-dispositive Motion Filing:

October 23, 2015

December 4, 2015

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Dispositive Motion Filing:

February 26, 2016

April 8, 2016

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For the reasons set forth herein, the parties therefore stipulate and agree to extend the

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foregoing deadlines as specified above. The parties request the court endorse this stipulation by way

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of formal order.
Respectfully submitted,

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Dated: August 13, 2015

BENJAMIN B. WAGNER
United States Attorney

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By:

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/s/Jeffrey J. Lodge
JEFFREY J. LODGE
Assistant U.S. Attorney
Attorneys for the United States

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Dated: August 14, 2015

PANISH SHEA & BOYLE LLP

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(As authorized 08/14/15)

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By:

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/s/David Rudorder
DAVID RUDORFER
Attorneys for Plaintiffs

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ORDER

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For good cause showing, IT IS HEREBY ORERED that the deadlines in this matter are

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ordered as outlined above.

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IT IS SO ORDERED.
Dated:

August 20, 2015

/s/ Sandra M. Snyder
UNITED STATES MAGISTRATE JUDGE

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STIPULATION EXTENDING SCHEDULING DEADLINES; [PROPOSED] ORDER

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STIPULATION EXTENDING SCHEDULING DEADLINES; [PROPOSED] ORDER

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