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STIPULATION AND PROPOSED ORDER CONTINUING ADDITIONAL PRETRIAL DATES

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KEESAL, YOUNG & LOGAN 

A Professional Corporation 

John D. Giffin, CASB NO. 89608 

John Cox, CASB NO 197687 

Four Embarcadero Center, Suite 1500 

San Francisco, California 94111 

Telephone: (415) 398-6000 

Facsimile: (415) 981-0136 

Attorneys for Defendant 

SOPHIE RICKMERS SCHIFFAHRTSGESELLSCHAFT mbH & CIE, KG. 

BANNING MICKLOW & BULL LLP 

Edward M. Bull, III, SBN 141996 

Eugene A. Brodsky, SBN 36691 

Jennifer L. Fiore, SBN 203618 

One Market, Steuart Tower, Suite 1440 

San Francisco, California 94105 

Telephone: (415) 399-9191 

Facsimile: (415) 399-9192 

Attorneys for Plaintiffs 

LESTER A. FERREIRA SR. 

and EVA JEAN FERREIRA 

NEUMILLER & BEARDSLEE 

Daniel S. Truax, SBN 157276 

P.O. Box 20 

Stockton, Ca 95201-3020 

Telephone: (209) 948-8200 

Facsimile: (209) 948-4910 

Attorneys for Defendant 

STOCKTON PORT DISTRICT 

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF CALIFORNIA 

LESTER A. FERREIRA, SR. and EVA JEAN 

FERREIRA, 

Plaintiffs, 

vs. 

M/V CCNI ANTOFAGASTA, her engines, 

tackle, apparel, furniture, etc. IN REM,

COMPANIA CHILENA de NAVEGACION 

INTEROCEANICA S.A., PORT OF 

STOCKTON, SECHSTE REEDEREI 

ALSTERUFER 26 GmbH & CIE. KG and 

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Case No. CIV. S-04-1916 MCE DAD 

STIPULATION AND ORDER 

CONTINUING ADDITIONAL PRETRIAL 

DATES 

Case 2:04-cv-01916-MCE -DAD Document 80 Filed 06/01/06 Page 1 of 4
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STIPULATION AND PROPOSED ORDER CONTINUING CERTAIN PRETRIAL DATES

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SOPHIE RICKMERS 

SCHIFFAHRTSGESELLSCHAFT mbH & CIE, 

KG., 

Defendants. 

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The parties to the above-entitled action, by and through their attorneys of record herein, jointly 

submit their Stipulation and Proposed Order Continuing Additional Pretrial Dates as follows: 

The parties are, as previously advised, engaged in settlement negotiations, are hopeful that 

these discussions will lead to an early resolution to this matter, and have selected Jerry Spolter, Esq. 

with JAMS in San Francisco as their private mediator. The parties have also obtained and confirmed a 

mediation date of June 22, 2006; the earliest date available that could be attended by all parties and 

that would facilitate the exchange of information between the parties needed for a productive 

mediation (including certain expert reports relating to damages). 

Because the parties hope to avoid the cost of preparing the pretrial submissions (as required by 

this Court’s Pretrial (Status) Scheduling Order) by settling this matter, the parties respectfully request 

that the court continue certain additional pretrial dates, namely the deadline for the submissions of the 

pretrial filings (currently June 12, 2006) and the pretrial conference (currently set for June 26, 2006) as 

follows:

(1) The pretrial filings currently due on June 12, 2006 be continued to June 30, 2006; 

(2) Exchange of rebuttal expert reports also be made on June 30, 2006; and 

(3) The pretrial conference currently set for June 26, 2006 at 2:30 p.m. be continued to July 

26, 2006 at 2:30 p.m. (with all other dates to remain the same). 

IT IS SO STIPULATED. 

DATED: May 24, 2006 KEESAL, YOUNG & LOGAN 

By: ____/s/ John D. Giffin_______

JOHN D. GIFFIN 

Attorneys for Defendant 

SOPHIE RICKMERS 

SCHIFFAHRTSGESELLSCHAFT mbH 

& CIE, KG. 

Case 2:04-cv-01916-MCE -DAD Document 80 Filed 06/01/06 Page 2 of 4
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STIPULATION AND PROPOSED ORDER CONTINUING CERTAIN PRETRIAL DATES

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DATED: May 24, 2006 BANNING MICKLOW & BULL LLP 

By:____/s/_Edward M. Bull, III

EDWARD M. BULL, III 

EUGENE A. BRODSKY 

JENNIFER L. FIORE 

Attorneys for Plaintiffs 

LESTER A. FERREIRA SR. 

and EVA JEAN FERREIRA 

DATED: May 24, 2006 NEUMILLER & BEARDSLEE 

By:___/s/ Daniel S. Truax________ 

DANIEL S. TRUAX 

Attorney for Defendant 

STOCKTON PORT DISTRICT 

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ORDER

Based on the stipulation of the parties and good cause appearing thereon, the Court hereby 

vacates the previously-set pretrial dates and amends the Court’s Scheduling Order as follows: 

(1) The pretrial filings currently due on June 12, 2006 are hereby continued to June 30, 

2006; 

(2) The exchange of rebuttal expert reports shall be made on June 30, 2006; and 

(3) The pretrial conference currently set for June 26, 2006 at 2:30 p.m. is hereby continued 

to July 17, 2006 at 1:30 p.m. Parties shall file a joint pretrial statement on or before 

July 3, 2006. 

(4) The jury trial date of August 9, 2006 is continued to September 6, 2006 at 09:00 a.m. 

All other pretrial dates to remain the same.

DATED: June 1, 2006 

__________________________________ 

MORRISON C. ENGLAND, JR 

UNITED STATES DISTRICT JUDGE

Case 2:04-cv-01916-MCE -DAD Document 80 Filed 06/01/06 Page 4 of 4