Ramirez v. BNSF Railway Company, et al
Filing
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STIPULATION and ORDER signed by Judge Garland E. Burrell, Jr. on 3/27/2014 ORDERING that the Scheduling Order is AMENDED as follows: Initial expert disclosures due 5/22/2014 and any contradictory and/or rebuttal expert disclosure are due by June 22, 2014; Each party will now be permitted twelve (12) total fact witness depositions. (Zignago, K.)
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FLESHER McKAGUE LLP
Jacob D. Flesher, SBN: 210565
Jason W. Schaff, SBN: 244285
193 Blue Ravine Road, Suite 265
Folsom, California 95630
Tele: 916/358-9042
Fax: 916/673-9672
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Attorneys for Defendant
BNSF Railway Company
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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GRACIELA RAMIREZ, Individually, as
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Successor in Interest of Decedent ALMA )
VIDRIO, and as Personal Representative of )
the ESTATE OF ALMA VIDRIO,
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Plaintiffs,
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vs.
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BNSF RAILWAY COMPANY, and AGUSTIN )
VIDRIO,
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Defendants.
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CASE NO.: 2:13-CV-00968-GEB-DAD
STIPULATION AND [PROPOSED]
ORDER TO AMEND SCHEDULING
ORDER
Trial Date: March 17, 2015
Whereas, the parties originally agreed to limit each party to ten depositions of
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fact witnesses, and the Court adopted that agreement in its pre-trial scheduling
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order;
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Whereas, the parties originally agreed to disclose expert witnesses by April 7,
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2014, and the Court adopted that agreement in its pre-trial scheduling order;
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Whereas, the parties have been unable to complete enough discovery to
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sufficiently prepare their respective experts due to circumstances outside of their
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control;
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-1Stipulation to Amend Scheduling Order
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Whereas, additional witnesses have been identified through the course of
discovery;
Whereas, the inability to prepare experts and the identification of new
witnesses presents good cause to amend the pre-trial scheduling order;
Whereas, no party will be prejudice by the proposed amendments,
The parties stipulate as follows:
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With the consent of the Court, The Pre-Scheduling Order will be
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amended to such that each party shall comply with Federal Rule of Civil Procedure
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26(a)(2)(B) and (C)’s initial expert disclosure requirements on or before May 22, 2014,
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and any contradictory and/or rebuttal expert disclosure authorized under Rule
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26(a)(2)(D)(ii) on or before June 22, 2014;
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2.
With the consent of the Court, the parties agree to allow two (2)
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additional fact witness depositions per side, such that each party will now be
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permitted twelve (12) total fact witness depositions.
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Dated: March 27, 2014
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MARY ALEXANDER & ASSOCIATES
/s/ MARY ALEXANDER
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MARY ALEXANDER
Attorneys for Plaintiff
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Dated: March 27, 2014
FLESHER McKAGUE LLP
/s/ JASON W. SCHAFF
_______________________________________________
JASON W. SCHAFF
Attorneys for Defendant
BNSF RAILWAY COMPANY
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-2Stipulation to Amend Scheduling Order
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IT IS SO ORDERED:
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Dated: March 27, 2014
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-3Stipulation to Amend Scheduling Order
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