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DALE L. ALLEN, JR., # 145279

JENNY LI, # 216900

LOW, BALL & LYNCH

505 Montgomery Street, 7th Floor

San Francisco, California 94111-2584

Telephone (415) 981-6630

Facsimile (415) 982-1634

Attorneys for Defendants

AZIZURANMAN RAHMANI,;

SAYED A. KARIMI dba ORANGE CAB COMPANY;

ORANGE CAB CO.; NATIONAL RAILROAD 

PASSENGER CORPORATION

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF CALIFORNIA

LORIE ALMAZAN and ESTHER GALVEZ,

Plaintiffs,

vs.

AZIZURANMAN RAHMANI,; SAYED A.

KARIMI, individually and dba ORANGE CAB

CO.; ORANGE CAB CO.; NATIONAL

RAILROAD PASSENGER CORPORATION and

DOES 1 through 20, 

Defendants.

 

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No. CIV-S-04-1872 MCE/PAN

STIPULATION AND 

ORDER CONTINUING TRIAL

DATE, FINAL PRETRIAL

CONFERENCE, AND EXPERT

DISCOVERY CUT-OFF

The present trial date is January 18, 2006. The present final pre-trial conference is December 5,

2005. Expert disclosures were due on November 15, 2005, with supplemental disclosures due on

November 30, 2005. Discovery closes on November 30, 2005.

The parties below hereby stipulate and agree to the following:

(1) That the January 18, 2006, trial date be vacated and continued to March 29, 2006, or as

soon thereafter as determined by the Court;

(2) That the Final Pretrial Conference of December 5, 2005, be vacated and continued to a

date in accordance with the new trial date, to be determined by the Court;

(3) That the due date for submission of the joint pretrial statement, currently November 21,

2005, be continued in accordance with the new trial date, to be determined by the Court;

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(4) That the due date for submission of trial exhibits, currently January 11, 2006, be

continued in accordance with the new trial date, to be determined by the Court;

(5) That the discovery cutoff date be continued to February 28, 2006; and

(6) That expert witness disclosures shall be exchanged on or before February 15, 2005, and 

supplemental disclosures shall be exchanged on or before February 28, 2005.

The parties request that this stipulation be adopted as the order of the court. Good cause exists to

grant this request for a short continuance. See Declaration of Dale Allen, filed concurrently herewith.

The parties sincerely wish to resolve this case through mediation, and request additional time to mediate

the case. Additionally, defendants’ trial counsel, Dale Allen, is set for a concurrent trial on January 16,

2006. This request is made in good faith, and the parties will make every effort to successfully mediate

this case. 

 

Dated: November 15, 2005.

LOW, BALL & LYNCH

 By /s/ Jenny Li 

DALE L. ALLEN, JR.

JENNY LI

Attorneys for Defendants

AZIZURANMAN RAHMANI,; SAYED A.

KARIMI dba ORANGE CAB COMPANY; 

ORANGE CAB CO.; NATIONAL RAILROAD

PASSENGER CORPORATION

Dated: November 15, 2005.

FURTADO JASPOVICE AND SIMONS

 By /s/ Martin L. Jaspovice 

MARTIN L. JASPOVICE

Attorneys for Plaintiffs 

ESTHER GALVEZ AND LORIE ALMAZAN

/ / /

/ / /

/ / /

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ORDER

Pursuant to the parties’ stipulation, the Court orders as follows:

(1) The January 18, 2006, trial date is vacated and continued to March 29, 2006 at 9:00 a.m.;

(2) The Final Pretrial Conference of December 5, 2005, is vacated and continued to February

13, 2006 at 1:30 p.m.;

(3) The joint pretrial statement is due for submission to the Court on or before January 30,

2006;

(4) Counsel shall produce all trial exhibits to the courtroom clerk no later that 3:00 p.m., on

March 22, 2006; 

(5) Discovery cutoff is continued to February 28, 2006; and

(6) Expert witness disclosures shall be exchanged on or before February 15, 2006, and

supplemental expert disclosures shall be exchanged on or before February 28, 2006.

IT IS SO ORDERED. 

Dated: November 17, 2005

___________________________________

MORRISON C. ENGLAND, JR

UNITED STATES DISTRICT JUDGE

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