Tompkins v. Union Pacific Railroad Company

Filing 206

STIPULATION AND ORDER signed by Magistrate Judge Craig M. Kellison on 12/23/2015 CONTINUING the hearing on 200 Motion for Reconsideration of Costs Taxed to 2/24/2016 at 10:00 AM in Redding (CMK) before Magistrate Judge Craig M. Kellison. (Michel, G.)

1 Anthony S. Petru, Esq., State Bar No. 91399
[e-mail]
2 Paula A. Rasmussen, Esq.
[e-mail]
3 HILDEBRAND, McLEOD & NELSON, LLP
Westlake Building
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4 350 Frank H. Ogawa Plaza, 4 Floor
Oakland, CA 94612
5 TEL: [phone]
FAX: [phone]
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Attorneys for Plaintiff
7 Burley D. Tompkins
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA – SACRAMENTO

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BURLEY D. TOMPKINS
Plaintiff,

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[phone]

ATTORNEYS AT LAW

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WESTLAKE BUILDING
350 FRANK H. OGAWA PLAZA, FOURTH FLOOR
OAKLAND CALIFORNIA 94612-2006

HILDEBRAND, MCLEOD & NELSON, INC.

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vs.

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UNION PACIFIC RAILROAD
COMPANY, a corporation,

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Defendant.

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CASE NO. 2:12-CV-01481-CMK
STIPULATION TO CONTINUE
PLAINTIFF’S MOTION FOR REVIEW
AND RECONSIDERATION OF TAXED
COSTS AND PROPOSED ORDER
Assigned to Hon. Craig M. Kellison
Trial Date:

August 24, 2015

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IT IS HEREBY STIPULATED AND AGREED by and between Defendant UNION

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PACIFIC RAILROAD COMPANY (hereinafter “UPRC”) and Plaintiff BURLEY S. TOMPKINS

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(hereinafter “Plaintiff”), by and through their respective counsel, to request the Court continue

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Plaintiff’s Motion for Review and Reconsideration of Taxed Costs currently scheduled for January

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26, 2016 at 10:00 a.m. before the Honorable Craig M. Kellison at the Redding Federal Courthouse,

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2986 Bechelli Lane, Redding, CA 96002 to February 24, 2016 at 10:00 a.m. at the same.

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Good cause exists to grant said continuance for the following:

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a. The parties are engaged in settlement discussions and continuing the hearing will allow

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for the facilitation of negotiations and settlement papers.
b. The parties stipulate that the briefing schedule will be based upon the February 24, 2016
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Stipulation Re Cont. Motion for Review
2:12-CV-01481-CMK

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hearing date.
c. No party will be prejudiced by the requested continuance.
d. Plaintiff will request the hearing be vacated and file the appropriate dismissal upon
receipt of signed settlement papers from Plaintiff.

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The parties attest that concurrence in the filing of the foregoing document has been obtained
from each of the signatories below.

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DATED: December 22, 2015

HILDEBRAND, McLEOD & NELSON, LLP
By:/s/ Paula A. Rasmussen
ANTHONY S. PETRU, ESQ.
PAULA A. RASMUSSEN, ESQ.
Attorney for Plaintiff
BURLEY TOMPKINS

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[phone]

ATTORN EYS AT LAW

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WEST LA KE BUILDI NG
350 FRA NK H. OGAWA P LAZA, FOURTH FLOOR
OAK LA ND CALIFORNIA 94612-2006

HILDEBRAND, MCLEOD & NELSON, INC.

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DATED: December 22, 2015

MURPHY, CAMPBELL, ALLISTON & QUINN

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By: /s/ Mariel Covarrubias
STEPHANIE L. QUINN SBN 216655
MARIEL COVARRUBIAS SBN 274784
Attorney for Defendant UNION PACIFIC
RAILROAD COMPANY

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IT IS SO ORDERED:

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Dated: December 23, 2015

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Stipulation Re Cont. Motion for Review
2:12-CV-01481-CMK