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STIPULATION AND PROPOSED ORDER CONTINUING CERTAIN PRETRIAL DATES

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KEESAL, YOUNG & LOGAN 

A Professional Corporation 

John D. Giffin, CASB NO. 89608 

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 & LOPEZ 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 

SOPHIE RICKMERS 

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

STIPULATION AND PROPOSED ORDER 

CONTINUING CERTAIN PRETRIAL 

DATES 

Case 2:04-cv-01916-MCE -DAD Document 72 Filed 05/18/06 Page 1 of 4
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SCHIFFAHRTSGESELLSCHAFT mbH & CIE, 

KG., 

Defendants. 

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I. INTRODUCTION 

Discovery in this matter is nearly complete. The parties have conducted depositions of all 

percipient witnesses. The parties have also propounded and responded to written discovery requests. 

All parties are working productively with one another to ensure that all discovery is concluded as soon 

as possible. 

The parties are engaged in settlement negotiations. They are hopeful that these discussions 

will lead to an early resolution to this matter. The parties wish to continue settlement discussions and 

are asking the Court to extend the expert cut-off date so that they will not have to incur additional 

expert fees at this time. 

The proposed expert discovery extension will still allow for expert designation and filing of 

reports over two months prior to the trial date. It will also give the parties five additional weeks to 

discuss resolution of the case before incurring significant fees and trial preparation costs. 

With these issues in mind, the parties have entered into the following stipulation and ask the 

Court to grant the attached Proposed Order. 

II. STIPULATION 

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

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

(1) The parties will make a good faith effort to complete private mediation of this matter 

prior to May 31, 2006. 

(2) Disclosure of experts be continued from April 28, 2006 to May 5, 2006; 

(3) Counter-designation of expert witnesses be continued to May 19, 2006; 

(4) Filing and exchange of expert reports be continued from April 28, 2006 to June 5, 

2006; 

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(5) Non-retained experts, including treating physicians, shall not be required to prepare 

reports, but will be subject to deposition prior to trial. 

IT IS SO STIPULATED. 

DATED: April 27, 2006 KEESAL, YOUNG & LOGAN 

By: ____/s/ John D. Giffin_______

JOHN D. GIFFIN 

Attorneys for Defendant 

SOPHIE RICKMERS 

SCHIFFAHRTSGESELLSCHAFT mbH 

& CIE, KG. 

DATED: April 27, 2006 BANNING MICKLOW BULL & LOPEZ 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: April 27, 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 parties shall make a good faith effort to complete private mediation prior to May 

31, 2006. 

(2) LAST DAY TO DISCLOSE EXPERTS IS CONTINUED FROM April 28, 2006 to 

May 5, 2006; 

(3) LAST DAY TO COUNTER-DESIGNATE EXPERT WITNESSES IS CONTINUED 

to May 19, 2006; 

(4) LAST DAY TO FILE AND EXCHANGE EXPERT REPORTS IS CONTINUED from 

April 28, 2006 to June 5, 2006; and 

(5) Non-retained experts including treating physicians shall not be required to prepare 

reports, but will be subject to deposition. 

DATED: May 17, 2006 

__________________________________ 

MORRISON C. ENGLAND, JR 

UNITED STATES DISTRICT JUDGE

Case 2:04-cv-01916-MCE -DAD Document 72 Filed 05/18/06 Page 4 of 4