Mangiaracina et al v. BNSF Railway Company et al

Filing 75

STIPULATION AND ORDER re 73 STIPULATION WITH PROPOSED ORDER CONTINUING MEDIATION DATE filed by Contra Costa County. Signed by Judge Jon S. Tigar on September 1, 2017. (wsn, COURT STAFF) (Filed on 9/1/2017)

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SHARON L. ANDERSON (SBN 94814)
County Counsel
CHRISTOPHER B. WHITMAN (SBN 223636)
Deputy County Counsel
COUNTY OF CONTRA COSTA
651 Pine Street, Ninth Floor
Martinez, California 94553
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Defendant
CONTRA COSTA COUNTY

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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JOEL MANGIARACINA and RANEE
CHALOEICHEEP,

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Plaintiffs,

No. 3:16-cv-05270-JST
STIPULATION AND [PROPOSED] ORDER
CONTINUING MEDIATION DATE

v.
BNSF RAILWAY COMPANY, a
corporation; NATIONAL RAILROAD
PASSENGER CORPORATION dba
AMTRAK; CONTRA COSTA
TRANSPORTATION AUTHORITY;
CONTRA COSTA COUNTY; and
DOES 1 to 50, inclusive,

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Courtroom 9, 19th Floor
The Honorable Jon S. Tigar
Date Action Filed: July 29, 2016
Trial Date: May 14, 2018

Defendants.

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STIPULATION

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IT IS HEREBY STIPULATED by and between Plaintiffs JOEL MANGIARACINA

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and RANEE CHALOEICHEEP (“Plaintiffs”), who are represented by Paula A. Rasmussen,

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Defendants BNSF RAILWAY COMPANY (“BNSF”) and NATIONAL RAILROAD

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PASSENGER CORPORATION dba AMTRAK (“Amtrak”), who are represented by Jeremy J.

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Schroeder, and Defendant CONTRA COSTA COUNTY (the “County”), who is represented

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by Christopher B. Whitman (collectively, “the parties”), that:

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STIPULATION AND [PROPOSED] ORDER CONTINUING MEDIATION DATE
Case No. 3:16-cv-05270-JST

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WHEREAS, in light of the discovery conducted to date in the instant matter, including

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unresolved issues with respect to coordinating depositions between the instant matter and

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Crane v. Mangiaracina, et al., Contra Costa County Superior Court Case No. C16-01418,

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there is good cause to continue the date of the mediation in the instant matter, currently

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scheduled for September 11, 2017; and
WHEREAS, the parties and the mediator, Craig Needham, have agreed to continue the

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mediation date and agreed on future availability dates.
IT IS HEREBY STIPULATED BY AND BETWEEN THE PARTIES THAT the

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mediation date be continued from September 11, 2017 to December 18, 2017.

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DATE: August 30, 2017

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HILDEBRAND, McLEOD & NELSON, LLP
By:

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DATE: August 30, 2017

/s/ Paula A. Rasmussen
PAULA A. RASUMUSSEN
Attorneys for Plaintiffs JOEL MANGIARACINA
and RANEE CHALOEICHEEP
FLESHER SCHAFF & SCHROEDER, INC.

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By:

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DATE: August 30, 2017

/s/ Jeremy J. Schroeder
JEREMY J. SCHROEDER
Attorneys for Defendants BNSF and Amtrak
SHARON L. ANDERSON, County Counsel

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By:

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/s/ Christopher B. Whitman
CHRISTOPHER B. WHITMAN
Deputy County Counsel
Attorneys for Defendant CONTRA COSTA
COUNTY

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STIPULATION AND [PROPOSED] ORDER CONTINUING MEDIATION DATE
Case No. 3:16-cv-05270-JST

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ATTORNEY ATTESTATION

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I hereby attest that I have authorization from all of the above-named counsel to E-file

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this statement, and this authority is reflected by the conformed signature (“/s/”) within this E-

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filed document.

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DATE: August 30, 2017

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SHARON L. ANDERSON, County Counsel
By:

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/s/ Christopher B. Whitman
CHRISTOPHER B. WHITMAN
Deputy County Counsel
Attorneys for Defendant CONTRA COSTA
COUNTY

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ORDER

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PURSUANT TO STIPULATION, IT IS ORDERED that there is good cause to
continue the mediation date from September 11, 2017 to December 18, 2017.
DATE: September 1, 2017

JON S. TIGAR
United States District Court Judge

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STIPULATION AND [PROPOSED] ORDER CONTINUING MEDIATION DATE
Case No. 3:16-cv-05270-JST

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