Ramirez v. BNSF Railway Company, et al

Filing 29

STIPULATION and ORDER signed by Judge Garland E. Burrell, Jr on 5/15/14 ORDERING that the Scheduling Order is AMENDED as follows; Initial Expert Disclosure due 6/6/2014, and any contradictory and/or rebuttal Expert Disclosure due on or before 7/5/2014. (Mena-Sanchez, L)

1
2
3
4

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: [phone]

5
6

Attorneys for Defendant
BNSF Railway Company

7
8

UNITED STATES DISTRICT COURT

9

EASTERN DISTRICT OF CALIFORNIA

10
11
12
13
14
15
16
17
18
19
20
21
22

GRACIELA RAMIREZ, Individually, as
)
Successor in Interest of Decedent ALMA )
VIDRIO, and as Personal Representative of )
the ESTATE OF ALMA VIDRIO,
)
)
Plaintiffs,
)
)
vs.
)
)
BNSF RAILWAY COMPANY, and AGUSTIN )
VIDRIO,
)
)
Defendants.
)
)

CASE NO.: 2:13-CV-00968-GEB-DAD
STIPULATION AND [PROPOSED]
ORDER TO AMEND SCHEDULING
ORDER
Trial Date: March 17, 2015

Whereas, the Court previously amended the Pre-Trial Scheduling Order to
extend the expert disclosure dates on stipulation of the parties;
Whereas, after the amendment, a homicide occurred in BNSF’s Klamath Falls

23

Yard involving two BNSF employees, which homicide required BNSF to cancel the

24

scheduled site inspections of its retained expert witnesses,

25

Pursuant to BNSF’s request, the parties stipulate as follows:

26

1.

27
28

With the consent of the Court, the Pre-Scheduling Order will be amended

such that each party shall comply with Federal Rule of Civil Procedure 26(a)(2)(B) and
-1Stipulation to Amend Scheduling Order
___________________________________________________________________________________________________

1

(C)’s initial expert disclosure requirements on or before June 6, 2014, and any

2

contradictory and/or rebuttal expert disclosure authorized under Rule 26(a)(2)(D)(ii)

3

on or before July 5, 2014.

4

IT IS SO STIPULATED.

5
6

Dated: May 1, 2014

7

MARY ALEXANDER & ASSOCIATES
/s/ MARY ALEXANDER
_______________________________________________
MARY ALEXANDER
Attorneys for Plaintiff

8
9
10
11
12

Dated: May 1, 2014

13

FLESHER McKAGUE LLP
/s/ JASON W. SCHAFF
_______________________________________________
JASON W. SCHAFF
Attorneys for Defendant
BNSF RAILWAY COMPANY

14
15
16
17
18
19
20

IT IS SO ORDERED:
Dated: May 15, 2014

21
22
23
24
25
26
27
28

-2Stipulation to Amend Scheduling Order
___________________________________________________________________________________________________