Tolliver v. Illinois Tool Works Inc.

Filing 21

STIPULATION AND ORDER re 17 . STIPULATION WITH PROPOSED ORDER CONTINUING INITIAL CASE MANAGEMENT CONFERENCE filed by Mary Tolliver, Illinois Tool Works Inc. Case Management Statement due by 5/31/2018. Initial Case Management Conference set for 6/12/2018 01:30 PM in Oakland, Courtroom 4, 3rd Floor. Signed by Magistrate Judge Kandis A. Westmore on 5/23/18. (sisS, COURT STAFF) (Filed on 5/23/2018)

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Brent M. Karren (State Bar No. 291038)
[e-mail]
Emily M. Westfall (State Bar No. 314769)
[e-mail]
MANNING GROSS + MASSENBURG LLP
201 Spear Street, Suite 1800
San Francisco, California 94105
Tel: [phone]
Fax: [phone]
Attorneys for Defendant
ILLINOIS TOOL WORKS INC.

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IN THE UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

LAW OFFICES OF

MANNING GROSS + MASSENBURG LLP

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MARY TOLLIVER, as heir to and
Case No.: 4:18-cv-01078-KAW
representative of the ESTATE OF JOHNNY
TOLLIVER, SR.; JOHNNY TOLLIVER, JR. Assigned to:
as surviving child of JOHNNY TOLLIVER, Hon. Kandis A. Westmore
SR.,
STIPULATION AND [PROPOSED] ORDER
Plaintiffs,
CONTINUING INITIAL CASE
MANAGEMENT CONFERENCE
vs.
TO JUNE 12, 2018 AT 1:30 PM
CRANE CARRIER, et al.,
Defendants.

Complaint Filed: December 12, 2017
Date Removed: February 20, 2018
Trial Date: Not SetTolliver -

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This Stipulation is entered into by and among the Plaintiffs and Nominal Defendants,

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MARY TOLLIVER, as heir to and representative of the ESTATE OF JOHNNY TOLLIVER, SR.;

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JOHNNY TOLLIVER, JR. as surviving child of JOHNNY TOLLIVER, SR; and ISAAC ISRAEL

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TOLLIVER, as surviving child of JOHNNY TOLLIVER, SR., by and through his mother and

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Guardian, ARIE CROCKETT (“Plaintiffs”), and Defendant, ILLINOIS TOOL WORKS INC.

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(“ITW”), answering party on behalf of named defendants Illinois Tool Works, Inc. and Crane

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Carrier, by and through their respective counsel;

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Whereas, lead trial counsel for ITW is unavailable on the scheduled date for the Initial Case
Management Conference on May 29, 2018;
Whereas, the parties anticipate consolidating the following two related matters:
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STIPULATION AND [PROPOSED] ORDER CONTINUING INITIAL CASE MANAGEMENT CONFERENCE

a. Isaac Israel Tolliver, as surviving child ofJohnny Tolliver, Sr., by and
through his mother and Guardian, Arie Crockett v. Crane Carrier Company,
et al; Case No. 4:18-cv-01091-SBA

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b. Mary Tolliver, as heir to and representative of the Estate ofJohnny Tolliver,
Sr., Johnny Tolliver, Jr., as surviving child ofJohnny Tolliver, Sr. v. Crane
Carrier, et al.; Case No. 4:18-cv-Ol 078-KA W

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Whereas, Counsel for all parties of record in both matters have met and conferred and agree
that June 12, 2018 is a mutually agreeable date for which all counsel will be available;
IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned
counsel for Plaintiffs and ITW, that:
1. All counsel of record agree to and request that the Court continue the Initial Case
Management Conference to June 12, 2018 at 1:30 P.M.

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2. All counsel of record agree to and request that the Court extend the deadline for filing

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a Joint Case Management Statement and making Rule 26 Disclosures to May 31, 2018.

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Dated: May

2018

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Elinor Leary, Esq.
David Winnett, Esq.,
Attorneys for Plaintiffs,
MARY TOLLIVER,
and JOHNNY TOLLIVER, JR.

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Dated: May 16

,2018

MANNING GROSS + MASSENBURG, LLP
Brent Karren, Esq.
Emily Westfall, Esq.,
Attorneys for Defendant,
ILLINOIS TOOL WORKS INC.
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STIPULATION AND [PROPOSED] ORDER CONTINUING INITIAL CASE MANAGEMENT CONFERENCE

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[PROPOSED] ORDER

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The above stipulation having been considered and good cause appearing therefore,

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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5/23/18
Dated: _________________________

______________________________________
The Honorable Kandis A. Westmore
MAGISTRATE JUDGE

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LAW OFFICES OF

MANNING GROSS + MASSENBURG LLP

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STIPULATION AND [PROPOSED] ORDER CONTINUING INITIAL CASE MANAGEMENT CONFERENCE