National Railroad Passenger Corporation et al v. State of California et al

Filing 82

STIPULATION and ORDER signed by District Judge Kimberly J. Mueller on 3/8/18: The parties have until March 30, 2018 to complete discovery in Phase Two of this litigation. (Kaminski, H)

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Kelsey A. Israel-Trummel
[e-mail]
JONES DAY
555 California Street, 26th Floor
San Francisco, CA 94104
Telephone: [phone]
Facsimile: +1.415.875.5700
Donald J. Munro (admitted pro hac vice)
[e-mail]
JONES DAY
51 Louisiana Avenue, NW
Washington, DC 20001
Telephone: [phone]
Facsimile: +1.202.626.1700
Attorneys for Plaintiffs
NATIONAL RAILROAD PASSENGER
CORPORATION, BNSF RAILWAY COMPANY,
UNION PACIFIC RAILROAD COMPANY, LOS
ANGELES JUNCTION RAILWAY, TTX
COMPANY, AND CENTRAL CALIFORNIA
TRACTION COMPANY

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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NATIONAL RAILROAD PASSENGER
CORPORATION (D/B/A AMTRAK), BNSF
RAILWAY COMPANY, UNION PACIFIC
RAILROAD COMPANY, LOS ANGELES
JUNCTION RAILWAY, TTX COMPANY,
and CENTRAL CALIFORNIA TRACTION
COMPANY,

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Case No. 2:15-cv-00924-KJM-EFB
JOINT STIPULATION AND ORDER
FOR EXTENSION OF DISCOVERY
DEADLINE

Plaintiffs,
v.
JULIE SU, in her official capacity as Labor
Commissioner, State of California Division of
Labor Standards Enforcement,
Defendant.

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JOINT STIPULATION AND ORDER FOR
EXTENSION OF DISCOVERY DEADLINE
Case No. 2:15-cv-00924-KJM-EFB

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Pursuant to Local Rule 143, Plaintiffs National Railroad Passenger Corporation (d/b/a

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Amtrak), BNSF Railway Company, Union Pacific Railroad Company, Los Angeles Junction

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Railway, TTX Company, and Central California Traction Company, Defendant Julie Su, and the
Union-Intervenors1 hereby submit this joint stipulation and proposed order for an extension of the

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discovery deadline. Per the Court’s Status (Pretrial Scheduling) Order (Phase Two), Dkt. No. 78,

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discovery concerning Phase Two of this litigation is scheduled to close on March 16, 2018. The

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parties jointly request an extension of that deadline until March 30, 2018. The parties have not

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previously sought any extensions of discovery in Phase Two of this litigation. The parties do not

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anticipate that any other deadlines will be affected by this extension.

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The Transportation Division of the International Association of Sheet Metal, Air, Rail and Transportation Workers;
Mechanical Division of the International Association of Sheet Metal, Air, Rail and Transportation Workers;
Brotherhood of Locomotive Engineers and Trainmen; International Brotherhood of Electrical Workers; National
Conference of Firemen & Oilers District of Local 32BJ, Service Employees International Union (SEIU);
Brotherhood of Railroad Signalmen; and Brotherhood of Maintenance of Way Employees Division/International
Brotherhood of Teamsters.
JOINT STIPULATION AND ORDER FOR
EXTENSION OF DISCOVERY DEADLINE
Case No. 2:15-cv-00924-KJM-EFB

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Respectfully submitted,

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Dated: March 6, 2018

JONES DAY
By: /s/ Kelsey Israel-Trummel
Kelsey Israel-Trummel
Donald J. Munro
Attorneys for Plaintiffs
NATIONAL PASSENGER RAILROAD CORPORATION,
BNSF RAILWAY COMPANY, UNION PACIFIC
RAILROAD COMPANY, LOS ANGELES JUNCTION
RAILWAY, TTX COMPANY AND CENTRAL
CALIFORNIA TRACTION COMPANY

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Dated: March 6, 2018

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By: /s/ Peter Chang (as authorized on March 5, 2018)
Peter Chang
455 Golden Gate Ave.
Suite 11000
San Francisco, CA 94102
Tel: [phone]
Fax: [phone]
[e-mail]
Attorneys for Defendant
JULIE SU, in her official capacity as Labor
Commissioner

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XAVIER BECERRA
Attorney General of California
TAMAR PACHTER
Supervising Deputy Attorney General

Dated: March 6, 2018

UNION-INTERVENORS

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By: /s/ Matthew J. Gauger (as authorized March 5, 2018)
Matthew J. Gauger
Weinberg Roger & Rosenfeld, PC
428 J Street
Suite 520
Sacramento, CA 95814-2341
[phone]
Fax: [phone]
[e-mail]

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Dated: March 6, 2018

SMART-TD
By: /s/ Erika Diehl-Gibbons (as authorized March 5, 2018)
Erika A. Diehl-Gibbons

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JOINT STIPULATION AND ORDER FOR
EXTENSION OF DISCOVERY DEADLINE
Case No. 2:15-cv-00924-KJM-EFB

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Kevin C. Brodar
SMART-TD
24950 Country Club Blvd., Ste. 340
North Olmsted, OH 44070
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Intervenor Plaintiff
TRANSPORTATION DIVISION OF THE
INTERNATIONAL ASSOCIATION OF SHEET METAL,
AIR, RAIL AND TRANSPORTATION WORKERS

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Dated: March 6, 2018

ZWERDLING, PAUL, KAHN & WOLLY, P.C.

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By: /s/ Michael S. Wolly (as authorized on March 5, 2018)
Michael S. Wolly
1025 Connecticut Avenue NW Ste. 712
Washington, DC 20036
Tel: [phone]
Fax: [phone]
[e-mail]
Attorney for Intervenor Plaintiffs
BROTHERHOOD OF LOCOMOTIVE ENGINEERS AND
TRAINMEN, NATIONAL CONFERENCE OF FIREMEN
& OILERS DISTRICT OF LOCAL 32BJ, SEIU, and
INTERNATIONAL BROTHERHOOD OF ELECTRICAL
WORKERS

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Dated: March 6, 2018

MOONEY, GREEN, SAINDON, MURPHY AND WELCH
PC

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By: /s/ Richard Edelman (as authorized on March 5, 2018)
Richard Edelman
1920 L Street NW, Suite 400
Washington, D.C. 20036
Tel: [phone]
Fax: [phone]
[e-mail]
Attorney for Intervenor Plaintiffs
BROTHERHOOD OF RAILROAD SIGNALMEN,
BROTHERHOOD OF MAINTENANCE OF WAY
EMPLOYEES DIVISION/IBT, and MECHANICAL
DIVISION OF THE INTERNATIONAL ASSOCIATION
OF SHEET METAL, AIR, RAIL AND
TRANSPORTATION WORKERS

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JOINT STIPULATION AND ORDER FOR
EXTENSION OF DISCOVERY DEADLINE
Case No. 2:15-cv-00924-KJM-EFB

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ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED that the parties have until March

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30, 2018 to complete discovery in Phase Two of this litigation.

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DATED: March 8, 2018.

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UNITED STATES DISTRICT JUDGE

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JOINT STIPULATION AND ORDER FOR
EXTENSION OF DISCOVERY DEADLINE
Case No. 2:15-cv-00924-KJM-EFB