Flores et al v. National Railroad Passenger Corporation et al
Filing
48
ORDER by Chief Magistrate Maria-Elena James granting 47 Motion for Extension of Time to Complete Discovery (rmm2S, COURT STAFF) (Filed on 12/11/2012)
1
4
Joel R. Bryant (State Bar No. 149370)
jbryant@gbflawyers.com
GREEN BRYANT & FRENCH LLP
1230 Columbia Street, Suite 1120
San Diego, California 92101
Tel: (619) 239-7900
Fax: (619) 239-7800
5
Attorneys for Plaintiffs
2
3
6
7
8
UNITED STATES DISTRICT COURT
9
NORTHERN DISTRICT OF CALIFORNIA
10
Flores et al.
Plaintiffs,
11
12
13
14
Case No. 3:12:CV-686-MEJ
v.
NATIONAL RAILROARD
PASSENGER CORP. dba
AMTRAK, et al.,
15
16
STIPULATION AND [PROPOSED]
ORDER TO CONTINUE DEADLINE
TO COMPLETE DISCOVERY
Trial Date:
Time:
Dept.:
Judge:
August 26, 2013
9:30 a.m.
Courtroom B, 15th Flr.
Hon. Maria Elena James
Defendants.
17
Pursuant to the Court’s July 26, 2012 Case Management Order, all discovery,
18
including depositions of expert witnesses, must be completed by February 19, 2013.
19
Plaintiffs and Defendants, National Railroad Passenger Corp. (“Amtrak”), Union
20
Pacific, and Monterey County, (collectively “Defendants”) by and through their
21
respective counsel, hereby stipulate and respectfully request to modify the Case
22
Management Order. Good cause exists to continue the discovery completion
23
deadline in order to facilitate further settlement discussions between parties, and
24
accommodate the litigation schedules of all counsel involved in this case.
25
NOW, THEREFORE, subject to the Court’s approval, the parties, through
26
their counsel of record, stipulate, agree, and respectfully request that the following
27
modifications to the Case Management Order shall be made:
28
G REEN B RYANT &
F RENCH , LLP
-1-
STIPULATION AND [PROPOSED] ORDER TO
CONTINUE DISCOVERY COMPLETION;
CASE NO. 3:12:CV-686-MEJ
1
2
3
4
5
6
7
8
9
10
11
1.
That the Disclosure of Expert Witnesses be continued from January
25, 2013 to March 26, 2013;
2.
That Disclosure of Rebuttal Expert Witnesses be continued from
February 4, 2013 to April 5, 2013;
3.
The Discovery cut-off be continued from February 19, 2013 to April
26, 2013;
4.
That the last day to file dispositive motions be continued from March
21, 2013 to May 20, 2013;
5.
That the last day to hear dispositive motions be continued from April
25, 2013 to June 24, 2013;
6.
That all other dates listed in the Case Management Order remain
12
unchanged. The initial pre-trial conference shall remain on July 25, 2013. The final
13
pre-trial conference shall remain on August 22, 2013, and trial shall remain
14
scheduled to commence on August 26, 2013.
15
16
Respectfully submitted,
17
18
19
GREEN BRYANT & FRENCH, LLP
Dated: December 11, 2012
20
21
/s/ Joel R. Bryant
Joel R. Bryant, Esq.
Jbryant@gbflawyers.com
Attorney for Plaintiffs
22
CHARLES J. McKEE, COUNTY COUNSEL
23
24
25
26
Dated: December 11, 2012
/s/ William M. Litt
William M. Litt
Deputy County Counsel
Attorney for Defendant, County of Monterey
27
28
G REEN B RYANT &
F RENCH , LLP
-2-
STIPULATION AND [PROPOSED] ORDER TO
CONTINUE DISCOVERY COMPLETION;
CASE NO. 3:12:CV-686-MEJ
1
2
3
4
5
LOMBARDI LOPER & CONANT
Dated: December 11, 2012
/s/ Vincent Castillo
Vincent Castillo
vcastillo@llcllp.com
Attorney for Defendants, Union Pacific Railroad
National Railroad Passenger Corporation
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
G REEN B RYANT &
F RENCH , LLP
-3-
STIPULATION AND [PROPOSED] ORDER TO
CONTINUE DISCOVERY COMPLETION;
CASE NO. 3:12:CV-686-MEJ
1
ORDER
2
3
4
5
6
7
8
9
10
11
12
13
14
15
PURSUANT TO STIPULATION, AND GOOD CAUSE APPEARING
THEREFORE, IT IS ORDERED THAT:
1.
That the Disclosure of Expert Witnesses be continued from January
25, 2013 to March 26, 2013;
2.
That Disclosure of Rebuttal Expert Witnesses be continued from
February 4, 2013 to April 5, 2013;
3.
The Discovery cut-off be continued from February 19, 2013 to April
26, 2013;
4.
That the last day to file dispositive motions be continued from March
21, 2013 to May 20, 2013;
5.
That the last day to hear dispositive motions be continued from April
25, 2013 to June 24, 2013;
6.
That all other dates listed in the Case Management Order remain
16
unchanged. The initial pre-trial conference shall remain on July 25, 2013. The final
17
pre-trial conference shall remain on August 22, 2013, and trial shall remain
18
scheduled to commence on August 26, 2013.
19
20
21
December 11,2012
Dated: ________________
______________________________
Hon. Maria Elena James
22
23
24
25
26
27
28
G REEN B RYANT &
F RENCH , LLP
-4-
STIPULATION AND [PROPOSED] ORDER TO
CONTINUE DISCOVERY COMPLETION;
CASE NO. 3:12:CV-686-MEJ
1
CERTIFICATE OF SERVICE
2
3
I hereby certify that a copy of the foregoing was electronically sent via the
4
Court’s electronic case filing system on December 11, 2012 to counsel for
5
Defendant.
6
7
GREEN BRYANT & FRENCH, LLP
8
9
Dated: December 11, 2012
10
11
/s/ Joel R. Bryant
Joel R. Bryant, Esq.
Jbryant@gbflawyers.com
Attorney for Plaintiffs
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-5-
G REEN B RYANT &
F RENCH , LLP
DCACTIVE-17851622.2
STIPULATION AND [PROPOSED] ORDER TO
CONTINUE DISCOVERY COMPLETION;
CASE NO. 3:12:CV-686-MEJ
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?