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LOMBARDI, LOPER

& CONANT, LLP

Lake Merritt Plaza 

1999 Harrison Street 

Suite 2600 

Oakland, CA 94612-3541

TEL: 510/433-2600 

FAX: 510/433-2699 

B. CLYDE HUTCHINSON, 037526 

AN H. NGUYEN, 215453 

LOMBARDI, LOPER & CONANT, LLP 

Lake Merritt Plaza 

1999 Harrison Street, Suite 2600 

Oakland, CA 94612-3541 

TEL: (510) 433-2600 

FAX: (510) 433-2699 

Attorneys for Defendant 

NATIONAL RAILROAD PASSENGER CORPORATION 

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF CALIFORNIA—SACRAMENTO DIVISION 

LORIE ALMAZAN and ESTHER GALVEZ, 

Plaintiffs, 

v. 

AZIZURANMAN RAHMANI, SAYED A. 

KARIMI, individually and dba ORANGE CAB 

CO.; ORANGE CAB CO.; NATIONAL 

RAILROAD PASSENGER CORPORATION 

and DOES 1 to 20, 

Defendants. 

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No. CIV S-04-1872 MCE PAN 

STIPULATION AND ORDER RE 

CONTINUANCE OF DISCOVERY 

CUT-OFF 

This lawsuit arises out of a motor vehicle collision on April 17, 2004 wherein plaintiffs 

allege that they were injured while riding in an Orange Cab Co. taxi, owned by SAYED A. 

KARIMI and operated by his agent, employee or contractor AZIZURANMAN RAHMANI. 

Plaintiffs filed suit against National Railroad Passenger Corporation (NRPC), SAYED A. 

KARIMI, Orange Cab Co., and AZIZURANMAN RAHMANI. Plaintiffs had made diligent 

efforts to serve all defendants but had been unable to locate SAYED A. KARIMI, Orange Cab Co., 

and AZIZURANMAN RAHMANI. 

The parties learned that Mr. Karimi had filed for bankruptcy protection. They have also 

been able to learn the identity of Mr. Karimi’s insurance carriers. NRPC has been in touch with the 

insurance carrier who is represented by Dale Allen Jr. of Low, Ball & Lynch. NRPC is in 

discussion with Mr. Allen’s client regarding the tender of its defense and indemnity of this matter. 

Case 2:04-cv-01872-MCE -PAN Document 15 Filed 07/06/05 Page 1 of 3
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LOMBARDI, LOPER

& CONANT, LLP

Lake Merritt Plaza 

1999 Harrison Street 

Suite 2600 

Oakland, CA 94612-3541

TEL: 510/433-2600 

FAX: 510/433-2699 

While the Court has granted the parties permission to serve additional parties, NPRC’s tender and 

Mr. Karimi’s bankruptcy status have delayed the litigation. 

Further, SAYED A. KARIMI, Orange Cab Co., and AZIZURANMAN RAHMANI have 

recently appeared in the action and discovery will need to be commenced against these defendants 

as well. 

The present discovery cut-off date is July 15, 2005. The parties hereby stipulate that the 

discovery cutoff be continued to September 15, 2005. The parties further stipulate that the expert 

witness disclosure be continued until September 15, 2005 with supplemental disclosures to occur 

on September 30, 2005. 

The parties request that this stipulation be adopted as the order of the court 

DATED: June 28, 2005 LOMBARDI, LOPER & CONANT, LLP 

By: /s/ An H. Nguyen 

An H. Nguyen 

Attorneys for Defendant 

NATIONAL RAILROAD PASSENGER 

CORPORATION 

DATED: June 27, 2005 FURTADO, JASPOVICE & SIMONS 

By: /s/ Martin L. Jaspovice 

Martin L. Jaspovice 

Attorneys for Plaintiffs 

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Case 2:04-cv-01872-MCE -PAN Document 15 Filed 07/06/05 Page 2 of 3
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LOMBARDI, LOPER

& CONANT, LLP

Lake Merritt Plaza 

1999 Harrison Street 

Suite 2600 

Oakland, CA 94612-3541

TEL: 510/433-2600 

FAX: 510/433-2699 

DATED: June 28, 2005 LOW, BALL & LYNCH 

By: /s/ Dale Allen, Jr. 

Dale Allen, Jr. 

Attorneys for Defendants SAYED A. KARIMI, 

Orange Cab Co., and AZIZURANMAN 

RAHMANI. 

ORDER

IT IS SO ORDERED. 

DATED: July 6, 2005 

__________________________________ 

MORRISON C. ENGLAND, JR 

UNITED STATES DISTRICT JUDGE 

Case 2:04-cv-01872-MCE -PAN Document 15 Filed 07/06/05 Page 3 of 3