Mrotz et al v. Union Pacific Railroad Company et al

Filing 16

STIPULATION AND ORDER signed by Judge John A. Mendez on 12/16/2014 ORDERING that expert witnesses be designated by 3/12/2015; ORDERING that rebuttal experts be designated by 3/20/2015; ORDERING that discovery be completed by 4/10/2015. (Michel, G)

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA ROBERT MROTZ, PATRICIA HAMAN Case. No. 2:14-cv-01271-JAM-CKD Plaintiffs, STIPULATION AND ORDER TO EXTEND DISCOVERY AND EXPERT WITNESS DISCLOSURE DATES v. NATIONAL RAILROAD PASSENGER CORPORATION, dba AMTRAK; UNION PACIFIC RAILROAD COMPANY and DOES 1 to 100 Defendants. ________________________________________/ Jacob D. Flesher, Esq. CSB # 210565 Jeremy J. Schroeder, Esq.CSB # 223118 Flesher McKague, LLP Attorneys for Defendants 193 Blue Ravine Road, Suite 265 Folsom, CA 95630 FAX (916) 673-9672 ______________________________/ Gregory J. Brod CSB # 184456 BROD LAW FIRM, P.C. Attorneys for Plaintiffs 96 Jessie Street San Francisco, CA 94105 FAX (415) 397-2121 Plaintiffs ROBERT MROTZ and PATRICIA HAMAN AND make the following Defendants, the NATIONAL RAILROAD PASSENGER CORPORATION, doing business as AMTRAK (hereinafter “AMTRAK”) and UNION PACIFIC RAILROAD COMPANY (hereinafter “UPRR”), by and thorough their respective attorneys, and jointly stipulate as follows: 1. On or about July 25, 2014, this Court ordered the parties to designate expert witnesses on January 16, 2105 and expert rebuttal by January 23, 2015. In addition, all discovery was to be completed by March 13, 2015; 2. Counsel for defendants, Jacob Flesher and Jeremy Schroeder, were engaged in a civil trial from November 3, 2014 through December 11, 2014, which has impacted the parties ability to exchange discovery and prepare for expert disclosures as they are currently set. The parties have agreed that a continuation of the discovery dates below would be beneficial to all parties involved; 3. The parties have exchanged initial disclosures, pursuant to FRCP 26(a)(1), and have been “meeting and conferring” over the course of several months regarding documents, primarily due to the trial schedules of counsel for all parties; 4. The parties have agreed to the following dates: a. Designation of Expert Witnesses: March 12, 2105; b. Expert Rebuttal due by: March 20, 2015; c. Discovery to be completed by: April 10, 2015. DATED: December ___, 2014 BROD LAW FIRM, PC. By _______________________________ GREGORY J. BROD, ESQ. Attorneys for plaintiffs ROBERT MROTZ and PATRICIA HAMAN DATED: December ___, 2014 FLESHER MCKAGUE LLP By _______________________________ JACOB D. FLESHER, ESQ. JEREMY J. SCHROEDER, ESQ. Attorneys for defendants, NATIONAL RAILROAD PASSENGER CORPORATION dba AMTRAK, and UNION PACIFIC RAILROAD COMPANY 2 DATED: 12/16/2014 /s/ John A. Mendez___________________ JUDGE OF THE U.S. DISTRICT COURT 3

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