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)

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 [phone]
______________________________/

Gregory J. Brod CSB # 184456
BROD LAW FIRM, P.C.
Attorneys for Plaintiffs
96 Jessie Street
San Francisco, CA 94105
FAX [phone]

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

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