Kessler v. National Railroad Passenger Corporation

Filing 10

STIPULATION and ORDER signed by Judge Garland E. Burrell, Jr. on 10/14/2015 ORDERING 9 Initial Expert Witnesses Disclosure due by 1/25/2016; Rebuttal Expert Witness Disclosure by 3/22/2016; and Discovery due by 4/22/2016. All other dates will remain the same as provided for in the 7/14/2015 scheduling order. (Reader, L)

(SPACE BELOW FOR FILING STAMP ONLY)
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STEPHANIE L. QUINN (SBN 216655)
RAYMOND TUASON (SBN 279346)
MURPHY, CAMPBELL, ALLISTON & QUINN
8801 Folsom Boulevard, Suite 230
Sacramento, CA 95826
Telephone: [phone]
Fax: [phone]
Attorneys for Defendant
NATIONAL RAILROAD PASSENGER
CORPORATION, dba AMTRAK

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA - SACRAMENTO

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LINDA KESSLER,

MURPHY, CAMPBELL, ALLISTON & QUINN

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Case No. 2:15-CV-00728-GEB-AC
Plaintiff,

v.
NATIONAL RAILROAD PASSENGER
CORPORATION, doing business as AMTRAK,
and DOES 1 through 10, inclusive,

STIPULATION OF THE PARTIES TO
MODIFY THE SCHEDULING ORDER
AND EXTEND DISCOVERY
DEADLINES;
[PROPOSED] ORDER

Defendants.

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STIPULATION OF THE PARTIES TO MODIFY THE SCHEDULING ORDER AND

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EXTEND DISCOVERY DEADLINES

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Pursuant to Rules 16(b)(4) and 29 of the Federal Rules of Civil Procedure, Defendant

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NATIONAL RAILROAD PASSENGER CORPORATION dba AMTRAK (“Defendant” or

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“AMTRAK”) and Plaintiff LINDA KESSLER (“Plaintiff” or “KESSLER”), by and through their

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attorneys of record, hereby stipulate to modify the scheduling order filed July 14, 2015, to

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extend the time for discovery deadlines previously set in this matter.

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The initial expert witness disclosure deadline is currently scheduled for November 24,
2015. The parties request a two month extension of this deadline to January 25, 2016.
The rebuttal expert witness disclosure deadline is currently scheduled for January 22,
2016. The parties request a two month extension of this deadline to March 22, 2016.

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STIPULATION TO MODIFY THE SCHEDULING ORDER AND EXTEND DISCOVERY DEADLINES; [PROPOSED] ORDER

Discovery is currently scheduled to be completed by March 22, 2016. The parties

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request a one month extension of this deadline to April 22, 2016.
All other dates will remain the same as provided for in the July 14, 2015 scheduling

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order.
GOOD

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CAUSE

EXISTS

FOR

THE

REQUESTED

MODIFICATIONS

AND

EXTENSIONS

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Defendant’s lead trial counsel, Stephanie Quinn, is currently on unexpected leave

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due to the very recent adoption of an infant. As such, Ms. Quinn will be unable to take

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Plaintiff’s deposition previously scheduled to take place on October 20, 2015.
Moreover, despite the parties’ diligent efforts to schedule the depositions of Plaintiff’s

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MURPHY, CAMPBELL, ALLISTON & QUINN

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medical treaters prior to the expert witness disclosure deadline, the parties will be unable to

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timely complete these depositions due to Ms. Quinn’s unexpected leave.
For these reasons, counsel for the parties have stipulated to modify the scheduling

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order and extend discovery deadlines.

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STIPULATION TO MODIFY THE SCHEDULING ORDER AND EXTEND DISCOVERY DEADLINES; [PROPOSED] ORDER

All other dates will remain the same as provided for in the July 14, 2015 scheduling

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order.
IT IS HEREBY STIPULATED
DATED: October 14, 2015

MURPHY, CAMPBELL, ALLISTON & QUINN

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By:

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/s/ RAYMOND TUASON
STEPHANIE L. QUINN (SBN 216655)
RAYMOND TUASON (SBN 279346)
Attorneys for Defendant
NATIONAL RAILROAD PASSENGER
CORPORATION, dba AMTRAK

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DATED: October 14, 2015

GANONG LAW

MURPHY, CAMPBELL, ALLISTON & QUINN

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By:

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/s/ PHILIP W. GANONG
PHILIP W. GANONG (SBN 88414)
Attorneys for Plaintiff LINDA KESSLER

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IT IS SO ORDERED:
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Dated: October 14, 2015
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STIPULATION TO MODIFY THE SCHEDULING ORDER AND EXTEND DISCOVERY DEADLINES; [PROPOSED] ORDER