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RANDOLPH, CREGGER & CHALFANT LLP

ADRIAN L. RANDOLPH, State Bar No. 133577

THOMAS A. CREGGER, State Bar No. 124402

STEPHANIE L. QUINN, State Bar No. 216655

1030 G Street

Sacramento, California 95814

Telephone: (916) 443-4443

Facsimile: (916) 443-2124

Attorneys for Defendant/Counter-Defendant

UNION PACIFIC RAILROAD COMPANY

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

DAVID CHAD GLOW,

Plaintiff,

vs.

UNION PACIFIC RAILROAD COMPANY,

HOWARD REDMOND, an individual, and Does 1

through 20, inclusive,

Defendants.

/

AND RELATED COUNTER-CLAIM

/

No. C 05 01933 MMC

SECOND STIPULATION

MODIFYING PRETRIAL

PREPARATION ORDER;

ORDER THEREON

COME NOW Plaintiff/Counter-Defendant DAVID CHAD GLOW, Defendant/CounterDefendant UNION PACIFIC RAILROAD COMPANY and Defendant/Counter-Claimant

HOWARD REDMOND who hereby enter into the following stipulation:

IT IS HEREBY STIPULATED THAT:

1. Non-expert discovery will be completed on or before September 5, 2006.

2. Expert disclosures are due on or before September 14, 2006. The parties hereby

waive the Federal Court Rule 26 provision requiring reports be completed and exchanged at the

time of disclosure and/or supplemental disclosure.

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SECOND STIPULATION AND ORDER

3. Supplemental expert disclosures are due on or before September 24, 2006.

4. Expert witness discovery will be completed on or before October 15, 2006.

5. Dispositive hearing motions will be filed no later than September 15, 2006.

6. Per the court’s prior order, the Pretrial Conference will be held on November 14,

2006 at 3:00 p.m. The Trial Date will be held on November 27, 2006 at 9:00 a.m. The parties

further agree that counter-part facsimile renditions of signatures are sufficient for entry of this

stipulation into the court files.

IT IS SO STIPULATED.

DATED: July 12, 2006 GANONG & WYATT

By /s/ Phillip W. Ganong 

Phillip W. Ganong

Attorneys for Plaintiff/Counter-Defendant

DATED: July 7 2006 LAW OFFICES OF JEAN SCHAEFER

By /s/ Jean Schaefer

Jean Schaefer

Attorney for Defendant/Counter-Claimant

DATED: July 12, 2006 RANDOLPH CREGGER & CHALFANT LLP

By /s/ Adrian L. Randolph 

Adrian L. Randolph

Attorneys for Defendant/Counter-Defendant 

ORDER

After considering the Stipulation by and between the parties, through their counsel of

record, IT IS HEREBY ORDERED THAT:

1. Non-expert discovery will be completed on or before September 5, 2006.

2. Expert disclosures are due on or before September 14, 2006. No reports shall be

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exchanged and filed at the time of disclosure and/or supplemental disclosure.

3. Supplemental expert disclosures are due on or before September 24, 2006.

4. Expert witness discovery will be completed on or before October 15, 2006.

5. Dispositive hearing motions will be filed no later than September 15, 2006.

6. Per the court’s prior order, the Pretrial Conference will be held on November 14,

2006 at 3:00 p.m. The Trial Date will be held on November 27, 2006 at 9:00 a.m. 

DATED: __________________

_________________________________________ MAXINE M. CHESNEY

U. S. DISTRICT JUDGE

July 14, 2006

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