On February 26, 2019 a
Stipulation,Agreement
was filed
involving a dispute between
Torres, Christopher,
Torres, Melissa,
and
Barnes Group Inc., As Successor By Acquisition Of Kar Products, Inc., A,
Barnes Group Inc. As Successor By Acquisition Of Kar Products,Llc,
B C Stocking Distributing, A California Corporation,
B'Laster Llc,
Chevron Corporation, A Delaware Corporation,
Chevron U.S.A. Inc,
Chevron U.S.A. Inc.,
Crc Industries, Inc. Which Will Do Businessin California As Pennsylvania Crc Industrie,
Dap Products Inc., A Delaware Corporation,
Does 3-100,
Husqvarna Professional Products, Inc., A Delaware Corporation,
Kern Oil & Refining Co., A California Corporation,
Lighthouse For The Blind,
Midwest Motor Supply Co., An Ohio Corporation,
Nch Corporation, A Delaware Corporation,
Oatey Co., An Ohio Corporation,
Pennzoil-Quaker State Company,
Petro Source Investments, Inc. A Delaware Corporation,
Ppg Industries, Inc. A Pennsylvania Corporation,
P-T Technologies, Inc., A Florida Corporation,
Quaker State Corporation, As Successor By Acquistion Of Westland Oil Company, Inc., A,
Safety-Kleen Systems, Inc., A Wisconsin Corporation,
Union Oil Company Of California, A California Corporation,
Wd-40 Company, A Delaware Corporation,
for Product Liability Unlimited
in the District Court of San Bernardino County.
Preview
\r
F:\WP\Cam\1515\STIPULAT\Confinuing Trial, rev‘d — wilh e—s'gsmpd
SUPE
F
METZGER LAW GROUP Comwggts’m 3E§§AL§ORW
SAN BERNARowo
Tox-TORT
561
| A PROFESSIONAL LAW CORPORATION msmw“
437-4499
RAPHAEL METZGER, ESQ, SBN 116020
”mm
"
DEC 2 ‘5
436—
WWW.TOX|CTORT$.COM
MONICA L. FRYE, ESQ, SBN 210183 2021
(877)
hWN
555 E. OCEAN BLVD, SUITE 800 '
(562) (562) LONG BEACH, CA 90802 -
TELEPHONE: (562) 437—4499
TOLL-FREE
TELECOPIER: (562) 436—1561 , em;
TELECOPIER
WEBSITE: www.toxictorts.com
TELEPHONE
Attorneys for Plaintiffs,
\OOONQLI’I
CHRISTOPHER TORRES and MELISSA TORRES
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
10 SAN BERNARDINO DISTRICT — CIVIL DIVISION
11
m
800
12 CHRISTOPHER TORRES and MELISSA CASE NO- CIVD31906092
‘
TORRES
SUITE 90802
CORPORATION
Re-Assigned t0 Honorable Bryan F. Foster,
GROUP 13
Dept. 5'22
Plaintiffs,
BOULEVARD,
14
LAW
LAw
CALIFORNIA
VS‘
STIPULATION AND
15
ORDER BRIEFLY CONTINUING TRIAL
SO THE DEPOSITIONS OF
METZGER
OCEAN
BEACH.
BARNES GROUP, INC., as successor by
PLAINTIFFS’ MEDICAL EXPERTS MAY
PROFESSIONAL
16 acquisition of Kar Products, Inc., a
Delaware corporation; B C STOCKING
BE TAKEN BEFORE FILING OF
EAST
LONG 17 DISTRIBUTING, a California corporation;
SUMMARY JUDGMENT MOTIONS
A
555
CHEVRON CORPORATION, a Delaware
18 corporation; CRC INDUSTRIES, INC.
WHICH WILL DO BUSINESS IN
19 CALIFORNIA AS PENNSYLVANIA
CRC INDUSTRIES, INC., a Pennsylvania
20 corporation; DAP PRODUCTS INC., a
Delaware corporation; et a1.,
21 ~
Defendants_
Trial Date: May 9, 2022
22
LUNG
23
INJURIES
TOXIC
24
LITIGATION
IN
TOXIC
ENVIRONMENTAL
25
AND
CONCENTRATED
ENVIRONMENTAL
8 26
CANCER,
27
8
OCCUPATIONAL
PRACTICE
DISEASE,
TORT
28
STIPULATION & PROPOSED ORDER BRIEFLY CONTINUING TRIAL SO THE DEPOSITIONS OF PLAINTIFFS’
MEDICAL EXPERTS MAY BE TAKEN BEFORE FILING OF SUMMARY JUDGMENT MOTIONS
V V
F:\WP\Cacas\1515\STlPULAT\Confinuhg Tr'al. rev'd -
wim e-sigs.wpd
This Stipulation is made by and between Plaintiffs, Christopher and Melissa Torres, and the
56| COM
Tox-TORT
| .
of record.
437-4499
Defendants in this action, by and through their respective attorneys
436—
.TOXICTORTS
¥UJN
(877)
(562) (562)
RECITALS
WWW
TOLL-FREE
TELECOPIER
TELEPHONE
The Stipulation is based upon the following facts:
\OOOQQUI
1. On October 4, 202 1 ,
the court granted a motion by Defendants, Chevron U.S.A. Inc.,
medical
and Union Oil Company ofCalifornia, for an early designation ofexpert witnesses regarding
10 causation so that Defendants could take the depositions of Plaintiffs’ expert
witnesses before filing
11 summary judgment motions. That order required the disclosure of expert witnesses regarding
800
12 medical causation to take place on November 30, 2021.
SUITE 90802
CORPORATION
13 2. On November 30, 2021, Plaintiffs designated their expert trial witnesses, including
GROUP
BOULEVARD.
CALIFORNIA 14 their expert witnesses regarding medical causation, and Defendants designated their expert witnesses
LAW
LAW
15 regarding medical causation.
was proposed by Defendants,
OCEAN
BEACH,
The schedule for expert witness depositions that
METZGER
PROFESSIONAL
16 3.
and Union Oil Company of California, and which was adopted by the Court,
EAST
LONG 17 Chevron U.S.A. Inc.,
A
555
18 called for Plaintiffs to produce all their expert witnesses regarding
medical causation for deposition
19 2022 (two weeks before the deadline for Defendants to file summary judgment
by January 7,
20 motions).
21 »
4. While Plaintiffs’ exposure assessment expert, Mark Nicas, cafi appear for hi-s expert
to appear for their
22 deposition by January 7, 2022, Plaintiffs’ medical experts are unavailable
23 depositions by January 7, 2022, due to holiday vacation plans and their busy schedules.
LUNG
INJUR|ES
TOXIC
24 5. Since Plaintiffs’ counsel could not produce their medical experts for their depositions
L|TIGATION
IN
ENVIRONMENTAL
TOXIC
Plaintiffs’ counsel contacted counsel for Defendants, Chevron U.S.A. Inc., and
25 by January 7, 2022,
AND
CONCENTRATED
5 26 Union Oil Company of California, who obtained the order requiring early expert designation, and
ENV|RONMENTAL
CANCER,
produce their medical
OCCUPATIONAL
27 requested a stipulation for a short continuance of trial, so that Plaintiffs could
8
PRACTICE
have time to thereafter prepare their
DISEASE.
TORT
28 experts for their expert designations and Defendants could still
1
STIPULATION AND PROPOSED ORDER BRIEFLY CONTINUING TRIAL SO THE DEPOSITIONS OF PLAINTIFFS’
MEDICAL EXPERTS MAY BE TAKEN BEFORE FILING OF SUMMARY JUDGMENT MOTIONS
Preview
\r F:\WP\Cam\1515\STIPULAT\Confinuing Trial, rev‘d — wilh e—s'gsmpd SUPE F METZGER LAW GROUP Comwggts’m 3E§§AL§ORW SAN BERNARowo Tox-TORT 561 | A PROFESSIONAL LAW CORPORATION msmw“ 437-4499 RAPHAEL METZGER, ESQ, SBN 116020 ”mm " DEC 2 ‘5 436— WWW.TOX|CTORT$.COM MONICA L. FRYE, ESQ, SBN 210183 2021 (877) hWN 555 E. OCEAN BLVD, SUITE 800 ' (562) (562) LONG BEACH, CA 90802 - TELEPHONE: (562) 437—4499 TOLL-FREE TELECOPIER: (562) 436—1561 , em; TELECOPIER WEBSITE: www.toxictorts.com TELEPHONE Attorneys for Plaintiffs, \OOONQLI’I CHRISTOPHER TORRES and MELISSA TORRES SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO 10 SAN BERNARDINO DISTRICT — CIVIL DIVISION 11 m 800 12 CHRISTOPHER TORRES and MELISSA CASE NO- CIVD31906092 ‘ TORRES SUITE 90802 CORPORATION Re-Assigned t0 Honorable Bryan F. Foster, GROUP 13 Dept. 5'22 Plaintiffs, BOULEVARD, 14 LAW LAw CALIFORNIA VS‘ STIPULATION AND 15 ORDER BRIEFLY CONTINUING TRIAL SO THE DEPOSITIONS OF METZGER OCEAN BEACH. BARNES GROUP, INC., as successor by PLAINTIFFS’ MEDICAL EXPERTS MAY PROFESSIONAL 16 acquisition of Kar Products, Inc., a Delaware corporation; B C STOCKING BE TAKEN BEFORE FILING OF EAST LONG 17 DISTRIBUTING, a California corporation; SUMMARY JUDGMENT MOTIONS A 555 CHEVRON CORPORATION, a Delaware 18 corporation; CRC INDUSTRIES, INC. WHICH WILL DO BUSINESS IN 19 CALIFORNIA AS PENNSYLVANIA CRC INDUSTRIES, INC., a Pennsylvania 20 corporation; DAP PRODUCTS INC., a Delaware corporation; et a1., 21 ~ Defendants_ Trial Date: May 9, 2022 22 LUNG 23 INJURIES TOXIC 24 LITIGATION IN TOXIC ENVIRONMENTAL 25 AND CONCENTRATED ENVIRONMENTAL 8 26 CANCER, 27 8 OCCUPATIONAL PRACTICE DISEASE, TORT 28 STIPULATION & PROPOSED ORDER BRIEFLY CONTINUING TRIAL SO THE DEPOSITIONS OF PLAINTIFFS’ MEDICAL EXPERTS MAY BE TAKEN BEFORE FILING OF SUMMARY JUDGMENT MOTIONS V V F:\WP\Cacas\1515\STlPULAT\Confinuhg Tr'al. rev'd - wim e-sigs.wpd This Stipulation is made by and between Plaintiffs, Christopher and Melissa Torres, and the 56| COM Tox-TORT | . of record. 437-4499 Defendants in this action, by and through their respective attorneys 436— .TOXICTORTS ¥UJN (877) (562) (562) RECITALS WWW TOLL-FREE TELECOPIER TELEPHONE The Stipulation is based upon the following facts: \OOOQQUI 1. On October 4, 202 1 , the court granted a motion by Defendants, Chevron U.S.A. Inc., medical and Union Oil Company ofCalifornia, for an early designation ofexpert witnesses regarding 10 causation so that Defendants could take the depositions of Plaintiffs’ expert witnesses before filing 11 summary judgment motions. That order required the disclosure of expert witnesses regarding 800 12 medical causation to take place on November 30, 2021. SUITE 90802 CORPORATION 13 2. On November 30, 2021, Plaintiffs designated their expert trial witnesses, including GROUP BOULEVARD. CALIFORNIA 14 their expert witnesses regarding medical causation, and Defendants designated their expert witnesses LAW LAW 15 regarding medical causation. was proposed by Defendants, OCEAN BEACH, The schedule for expert witness depositions that METZGER PROFESSIONAL 16 3. and Union Oil Company of California, and which was adopted by the Court, EAST LONG 17 Chevron U.S.A. Inc., A 555 18 called for Plaintiffs to produce all their expert witnesses regarding medical causation for deposition 19 2022 (two weeks before the deadline for Defendants to file summary judgment by January 7, 20 motions). 21 » 4. While Plaintiffs’ exposure assessment expert, Mark Nicas, cafi appear for hi-s expert to appear for their 22 deposition by January 7, 2022, Plaintiffs’ medical experts are unavailable 23 depositions by January 7, 2022, due to holiday vacation plans and their busy schedules. LUNG INJUR|ES TOXIC 24 5. Since Plaintiffs’ counsel could not produce their medical experts for their depositions L|TIGATION IN ENVIRONMENTAL TOXIC Plaintiffs’ counsel contacted counsel for Defendants, Chevron U.S.A. Inc., and 25 by January 7, 2022, AND CONCENTRATED 5 26 Union Oil Company of California, who obtained the order requiring early expert designation, and ENV|RONMENTAL CANCER, produce their medical OCCUPATIONAL 27 requested a stipulation for a short continuance of trial, so that Plaintiffs could 8 PRACTICE have time to thereafter prepare their DISEASE. TORT 28 experts for their expert designations and Defendants could still 1 STIPULATION AND PROPOSED ORDER BRIEFLY CONTINUING TRIAL SO THE DEPOSITIONS OF PLAINTIFFS’ MEDICAL EXPERTS MAY BE TAKEN BEFORE FILING OF SUMMARY JUDGMENT MOTIONS