Griffin v. Union Pacific Railroad Company

Filing 54

STIPULATION and ORDER 53 Continuing the Trial, signed by Magistrate Judge Jennifer L. Thurston on 1/10/2019. Jury Trial CONTINUED to 2/12/2019 at 08:30 AM in Bakersfield, 510 19th Street before Magistrate Judge Jennifer L. Thurston. Trial submissions due by 1/25/2019. Exhibit binders due by 2/8/2019. Defendant's expert witness will be permitted to testify via teleconference or videoconference, if necessary. (Hall, S)

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DANIEL RODRIGUEZ, ESQ., SBN 096625
JOEL T. ANDREESEN, ESQ. SBN 152254
DANIEL TUREK, ESQ. 318797
RODRIGUEZ & ASSOCIATES,
A PROFESSIONAL LAW CORPORATION
2020 EYE STREET
BAKERSFIELD, CA 93301
PHONE [phone] FAX [phone]
Attorneys for Plaintiff
JOHNNY GRIFFIN

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Stephanie L. Quinn (SBN 216655)
Mariel Covarrubias (SBN 274784)
MURPHY, CAMPBELL, ALLISTON & QUINN
8801 Folsom Boulevard, Suite 230
Sacramento, CA 95826
Phone: [phone]
Fax: [phone]
[e-mail]
[e-mail]

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Attorneys for Defendant
UNION PACIFIC RAILROAD COMPANY

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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)
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Plaintiff,
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vs.
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UNION PACIFIC RAILROAD COMPANY, )
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and DOES 1 through 10, inclusive
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Defendants.
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JOHNNY GRIFFIN

Case No.: 1:17-cv-00384-LJO-JLT
JOINT STIPULATION REGARDING
CONTINUANCE OF TRIAL AND
RELATED DATES; [PROPOSED]
ORDER
(Doc. 53)

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Plaintiff JOHNNY GRIFFIN and Defendant UNION PACIFIC RAILROAD COMPANY

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by and through respective counsel, hereby submit the following stipulation to continue trial

JOINT STIPULATION REGARDING CONTINUANCE OF TRIAL AND RELATED DATES
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and related dates. After meeting and conferring, the parties hereby stipulate to the

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following:

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1.

Trial date of January 28, 2019 at 8:30 a.m., pursuant to section D of the

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Pretrial Order (DOC 33), be vacated and continued to February 12, 2019 at

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8:30 a.m.;

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2.

January 11, 2019 date to submit final lists of respective exhibits, pursuant to

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section M.2. of the Pretrial Order (DOC 33), be vacated and continued to

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January 25, 2019;

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3.

January 25, 2019 date to submit all pre-marked trial exhibits to the courtroom

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deputy, pursuant to section M.3. of the Pretrial Order (DOC 33), be vacated

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and continued to February 8, 2019;

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4.

Pretrial Order (DOC 33), be vacated and continued to January 25, 2019;

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January 11, 2019 date to submit trial briefs, pursuant to section N of the

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January 11, 2019 date to submit proposed jury voir dire, pursuant to section

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U of the Pretrial Order (DOC 33), be vacated and continued to January 25,

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2019;

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6.

January 11, 2019 date to submit jury instructions and verdict form, pursuant

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to section V of the Pretrial Order (DOC 33), be vacated and continued to

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January 25, 2019;

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7.

Defendant’s expert witness, Dr. Sassan Keshavarzi, will be permitted to
testify via teleconference, if necessary.

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JOINT STIPULATION REGARDING CONTINUANCE OF TRIAL AND RELATED DATES
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DATED: January 9, 2019

RODRIGUEZ & ASSOCIATES

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By:

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/s/ Daniel Turek
DANIEL RODRIGUEZ
DANIEL TUREK
Attorneys for Plaintiff Johnny Griffin

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DATED: January 9, 2019

MURPHY, CAMPBELL, ALLISTON, & QUINN

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By:

/s/ Mariel Covarrubias
STEPHANIE L. QUINN
MARIEL COVARRUBIAS
Attorneys for Defendant Union Pacific Railroad Co.

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JOINT STIPULATION REGARDING CONTINUANCE OF TRIAL AND RELATED DATES
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[PROPOSED] ORDER

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Based on the Stipulation of the Parties, the Court ORDERS:

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1.

The trial is continued to February 12, 2019 at 8:30 a.m.;

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2.

The parties SHALL file their final exhibit list (Doc. 33 at 10) by January 25, 2019;

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3.

The parties SHALL submit the pre-marked trial exhibit binders to the courtroom deputy
by February 8, 2019;

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4.

The parties SHALL may file trial briefs no later than January 25, 2019;

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5.

The parties SHALL file proposed jury voir dire no later than January 25, 2019;

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6.

The parties SHALL file their proposed jury instructions and verdict form no later than
January 25, 2019;

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7.

Defendant’s expert witness, Dr. Sassan Keshavarzi, will be permitted to testify via

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teleconference or videoconference, if necessary. However, defense counsel SHALL

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contact

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[e-mail]. to arrange a test of the teleconference or videoconference no

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later than January 18, 2019.

Courtroom

Deputy

Clerk,

Susan

Hall,

at

(661)-326-6620

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IT IS SO ORDERED.
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Dated:

January 10, 2019

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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[PROPOSED] ORDER TO CONTINUE TRIAL AND RELATED DATES
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or