Oscar Winski Company, Inc. v. Block and Company, Inc.

MOTION

N.D. Ill.May 8, 2020

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS OSCAR WINSKI COMPANY, INC. Plaintiff, v. MIDLAND STAMPING AND FABRICATING CORP., Defendant. ) ) ) ) ) ) ) ) ) ) ) Case No. 19-cv-06976 The Honorable Sharon Johnson Coleman Magistrate Judge Young B. Kim DEFENDANT MIDLAND STAMPING AND FABRICATING CORP.’S MOTION FOR WITHDRAWAL AND SUBSTITUTION OF COUNSEL Defendant Midland Stamping and Fabricating Corp. requests, pursuant to Local Rule 83.17, that attorney Todd C. Toral, with the firm Jenner & Block LLP, be permitted to substitute in as lead attorney and counsel of record for Midland in place of prior counsel of record, Timothy R. Herman, with the firm Clark Hill PLC. By substitution of attorney Toral, attorney Herman requests that he be permitted to withdraw from the representation of Midland. In support of this motion, Midland states as follows: 1. Midland wishes to change its counsel in the above-captioned action, by substituting Todd C. Toral of Jenner & Block LLP as counsel of record for Midland, in place of Timothy R. Herman of firm Clark Hill PLC, who has filed an appearance on behalf of Midland in this action. 2. Attorney Daniel W. Bobier, an attorney at Jenner & Block LLP with attorney Toral, is admitted to practice in the United States District Court for the Northern District of Illinois and has filed an appearance for Midland. 3. Attorney Toral has filed a Motion for Leave to Appear Pro Hac Vice that is pending. 4. Midland does not submit this Motion for the purpose of causing any delay. Case: 1:19-cv-06976 Document #: 42 Filed: 05/08/20 Page 1 of 3 PageID #:268 2 WHEREFORE, the undersigned counsel respectfully request that the Court enter an order granting Midland’s motion to substitute attorney Todd C. Toral of Jenner & Block LLP as lead attorney and counsel of record in place of attorney Timothy R. Herman of firm Clark Hill PLC, and permitting Timothy R. Herman to withdraw. Dated: May 8, 2020 Respectfully Submitted, /s/ Timothy R. Herman (with permission) Timothy R. Herman CLARK HILL PLC 130 E. Randolph Street, Suite 3900 Chicago, Illinois 60601 Tel. (312) 985-5900 therman@clarkhill.com /s/ Todd C. Toral Todd C. Toral (Pro Hac Vice Pending) JENNER & BLOCK LLP 633 West 5th Street, Suite 3600 Los Angeles, CA 90071-2054 Tel. (213) 239-5100 ttoral@jenner.com Counsel for Midland Stamping and Fabricating Corp. Case: 1:19-cv-06976 Document #: 42 Filed: 05/08/20 Page 2 of 3 PageID #:269 3 CERTIFICATE OF SERVICE I hereby certify that on May 8, 2020, I caused the foregoing to be electronically filed with the Clerk of the Court by using the CM/ECF system, which will send a notice of electronic filing to all CM/ECF participants. Dated: May 8, 2020] /s/ Todd C. Toral Todd C. Toral JENNER & BLOCK LLP 633 West 5th Street, Suite 3600 Los Angeles, CA 90071-2054 Tel. (213) 239-5100 ttoral@jenner.com Case: 1:19-cv-06976 Document #: 42 Filed: 05/08/20 Page 3 of 3 PageID #:270