Cornell v. Columbus McKinnon Corporation et al

Filing 134

ORDER TO REOPEN DISCOVERY AS TO DAMAGES ONLY, Motions terminated: 124 MOTION to Continue and Reopen Discovery as to Damages Only and Continue Trial, or, in the Alternative, Bifurcate Trial filed by YALE INDUSTRIAL PRODUCTS, INC... Signed by Judge Susan Illston on 3/16/16. (tfS, COURT STAFF) (Filed on 3/16/2016)

1 S. Christian Stouder (Bar No. 149821)
[e-mail]
2 Krsto Mijanovic (Bar No. 205060)
[e-mail]
3 Leah B. Mason (Bar No. 240425)
[e-mail]
4 HAIGHT BROWN & BONESTEEL LLP
555 South Flower Street, Forty-Fifth Floor
5 Los Angeles, California 90071
Telephone: [phone]
6 Facsimile: 213.542.8100
7 Craig A. Leslie (pro hac vice)
[e-mail]
8 Michael B. Powers (pro hac vice)
[e-mail]
9 PHILLIPS LYTLE LLP
One Canalside
10 125 Main Street
Buffalo, New York 14203
11 Telephone: [phone]
Facsimile: 716.852.6100
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Attorneys for Defendant
13 Yale Industrial Products, Inc.
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION

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Hon. Susan Illston
Courtroom 1

Plaintiff,

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Case No. 3:13-cv-02188 SI

BRIAN CORNELL,

v.

STIPULATION TO REOPEN
DISCOVERY AS TO DAMAGES
ONLY

COLUMBUS McKINNON
21 CORPORATION; AUTOQUIP
CORPORATION, YALE
22 INDUSTRIAL PRODUCTS, INC. and
DOES 1-200, inclusive,
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Defendant.
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CK06-0000001
11894093.1

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Case No. 3:13-cv-02188 SI
STIPULATION

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IT IS HEREBY stipulated by and between the parties as follows:

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WHEREAS, on February 26, 2016, Defendants filed a Motion to Continue

3 and Reopen Discovery as to Damages Only and Continue Trial, or, in the
4 Alternative, Bifurcate Trial;
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WHEREAS, Counsel for all parties have conferred and agreed, subject to the

6 Court’s consent, to reopen discovery as to damages only;
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THE PARTIES STIPULATE THAT:

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Yale’s Motion to Continue and Reopen Discovery as to Damages Only and

9 Continue Trial, or, in the Alternative, Bifurcate Trial, shall be withdrawn upon the
10 Court granting this Stipulation;
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On or before March 29, 2016, Plaintiff shall provide Defendants with updated

12 medical records, including for his recent revision surgery, and thereafter continue to
13 do so through the date of trial;
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Plaintiff agrees to submit to a further independent medical examination by Dr.

15 Lawrence Oloff, DPM, FACFAS, at a mutually agreeable date and time;
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It is further agreed that, should Yale seek additional damages discovery, the

17 parties will meet and confer regarding the same, and avail themselves of the Court’s
18 joint discovery letter practice, if necessary.
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I agree to and accept the foregoing stipulation.

20 DATED: March 15, 2016

WALKUP, MELODIA, KELLY & SCHOENBERGER

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/s/ Khaldoun A. Baghdadi
KHALDOUN A. BAGHDADI
Attorneys for Plaintiff

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25 DATED: March 15, 2016
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HAIGHT BROWN & BONESTEEL LLP
/s/ Krsto Mijanovic
KRSTO MIJANOVIC
Attorneys for Defendants

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CK06-0000001
11894093.1

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Case No. 3:13-cv-02188 SI
STIPULATION

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Pursuant to the stipulation of the parties, and good cause appearing,
IT IS ORDERED THAT:
Defendant Yale Industrial Products, Inc.’s pending Motion to Continue and
Reopen Discovery as to Damages Only and Continue Trial, or, in the Alternative,
Bifurcate Trial, is withdrawn, and discovery is reopened as to damages only.

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8 DATED: March __, 2016

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Hon. Susan Illston
United States District Judge

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CK06-0000001
11894093.1

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Case No. 3:13-cv-02188 SI
STIPULATION