STIPULATION AND ORDER GRANTING LEAVE TO FILE FIRST AMENDED COMPLAINT

TROY L. NUNLEY, District Judge.

Plaintiff, KATIE M. STEFFEN, and defendants UNION PACIFIC RAILROAD COMPANY, a Delaware Corporation, and BRIAN L. KLINE, submit the following Joint Stipulation and request that the Court grant Plaintiff leave to add PACIFIC EXCAVATION, INC. and M & M ELECTRIC to this action and file a First Amended Complaint pursuant to Rule 15(a) of the Federal Rules of Civil Procedure:

1. Plaintiff filed her complaint on April 7, 2016 in Yolo County Superior Court;

2. On May 11, 2015, Defendants removed Plaintiff's complaint to the Eastern District of California;

3. On May 11, 2015, Defendants filed and served their answer to Plaintiff's complaint;

4. While in the course of taking depositions and other discovery, Union Pacific has developed a new defense, that another entity may be liable to the Plaintiff, based on what is now believed to be a potentially faulty installation and/or design of a breakaway light pole that Plaintiff's vehicle struck at the time of the accident.

6. The parties have met and conferred regarding the addition of Defendants in Plaintiff's proposed First Amended Complaint and Defendants have agreed to Plaintiff's request for this stipulation.

NOW, THEREFORE, the parties hereby stipulate and request that the Court grant Plaintiff's leave to file a First Amended Complaint in this action, which is to be filed within fourteen (14) days of this Order.

IT IS SO STIPULATED.

ORDER

Good cause appearing, IT IS HEREBY ORDERED that Plaintiff is granted leave to file the First Amended Complaint, which is to be filed within fourteen (14) days of this Order.