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STIPULATION AND ORDER

RANDOLPH, CREGGER & CHALFANT LLP

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

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. Discovery will be re-opened regarding Plaintiff’s medical condition and

employability status post surgery, including but not limited to a second defense independent

medical examination with Dr. Mills and Plaintiff’s deposition.

2. Non-expert discovery will be re-opened, to be limited to deposing Plaintiff 

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STIPULATION AND ORDER

regarding his status post surgery. Non-expert discovery will be completed on or before July 27,

2007.

3. Expert discovery will be completed on or before July 27, 2007.

4. Per the court’s prior order, the Pretrial Conference will be held on August 14, 2007

at 3:00 p.m. The Trial Date will be held on August 27, 2007 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 2, 2007 GANONG & WYATT

By /s/ PHILLIP W. GANONG 

Phillip W. Ganong

Attorneys for Plaintiff/Counter-Defendant

DATED: July 2, 2007 LAW OFFICES OF JEAN SCHAEFER

By /s/ JEAN SCHAEFER

Jean Schaefer

Attorney for Defendant/Counter-Claimant

DATED: July 2, 2007 RANDOLPH CREGGER & CHALFANT LLP

By /s/ THOMAS A. CREGGER

Thomas A. Cregger

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. Discovery will be re-opened regarding Plaintiff’s medical condition and

employability status post surgery, including but not limited to a second defense independent

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medical examination and Plaintiff’s deposition.

2. Non-expert discovery the for the limited purpose of deposing Plaintiff regarding his

status post surgery will be completed on or before July 27, 2007.

3. Expert discovery will be completed on or before July 27, 2007.

4. Per the court’s prior order, the Pretrial Conference will be held on August 14, 2007

at 3:00 p.m. The Trial Date will be held on August 27, 2007 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.

DATED: __________________

_________________________________________

MAXINE M. CHESNEY

U. S. DISTRICT JUDGE

July 3, 2007

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