On May 25, 2017 a
Party Discovery
was filed
involving a dispute between
Avalos, Jessie,
Columbia Steel, Inc. An Unknown California Corporation,
Morton, Thomas,
Willhite, Merlin,
and
Columbia Steel, Inc. An Unknown California Corporation,
Morton, Thomas,
Rollins, Charley,
Rollins, Lorea,
Willhite, Merlin,
for PI Motor Vehicle
in the District Court of San Bernardino County.
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aNA
8
1 RESNICK LOUIS P C SUPERIOR COURT flF CALIFORNIA
COUN Y OF SAN BERNAFtDiNO
Lisa M Bolle E sq SBN 282791 SAN BERNARDINO DISTRICT
2
9891 Irvine Center Dr Suite 200
R 1 5 2 9
Irvine CA 92618
A
3
Telephone 714 709 4400
4 714 709 4400 j
Facsimile BY
Email lbolle a rlattorne s
MELIS5A WNITE DEPUN
C 5
Attorneysfor Defendants Cross Defendants Cross Complainants Thomas Morton and Tracey
Landon
C 1
C 1
SUPERIOR COURT OF THE STATE OF CALIFORNIA
8
j
9 FOR THE COUNTY OF SAN BERNARDINO
10 SSIE AVALOS an individual Case No CIVDS1709871
11
Plaintiff
DEFENDANTS THOMAS MORTON
12
vs AND TRACEY LANDON S NOTICE
13 OF MOTION AND MOTION FOR
CHARLEY ROLLINS an individual GOOD FAITH SETTLEMENT
14 LOREA ROLLINS an individual DETERMINATION MEMORANDUIVI
THOMAS MORTON an individual OF POINTS AND AUTHORITIES
15
MERLIN WILLHITE COLLTMBIA DECLARATION OF LISA BOLLE
16 STEEL INC and DOES 1 through 20 AND PROPOSED ORDER
Inclusive
1
1g Defendants Action Filed May 25 2017
Trial July 15 2019
19
AND ALL RELATED CROSS ACTION
20
21 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD
22 PLEASE TAKE NOTICE that Defendants Cross Complainants Cross Defendants Thomas
23 Morton and Tracey Landon hereinafter Settlors by and through the undersigned counsel will
24 apply for an order determining the settlement entered into between Plaintiff Jessie Avalos
25 hereinafter Plaintiffl and Settlors was made in good faith pursuant to California Code of Civil
26 Procedure sections 877 and 877 6 a 2
27 Settlors and Plaintiff have settled for the Settlors limits of 100 000 00 with the
policy
28 settling parties to bear their own costs and attorneys fees
THOMAS MORTON TRACEY LANDON S MOTION FOR GOOD FAITH SETTLEMENT DETERMINATION
1
1 The Settlors also request an order dismissing the pending cross complaints by Merlin
2 Willhite and Columbia Steele Inc against Settlors and for an order barring any future cross
3 complaints for indemnity or contribution based on negligence comparative negligence or
4 comparative fault against the Settlors
5 Pursuant to California Rules of Court Rule 3 1382 the following pleadings will be affected
6 by the settlement
7 1 Complaint filed by Plaintiff on May 25 2017
8 2 Cross Complaint against the Settlors filed by Merlin Willhite and Columbia Steel
9 Inc on July 25 2017
10 3 Cross Complaint filed by the Settlors against Charley Rollins Lorea Rollins Merlin
ll Willhite and Columbia Steel Inc on September 29 2017
12 4 Answer to Cross Complaint of Merlin Whillhite and Columbia Steel Inc filed by the
13 Settlor Thomas Morton on September 29 2017
14 5 Answer to Cross Complaint of Merlin Whillhite and Columbia Steel Inc filed by the
15 Settlor Tracey Landon on December 4 2017
16 This Application will be based on the following Memorandum of Points and Authorities the
17 Declaration of Lisa Bolle and allthe pleadings records and papers on file herein
18
19 DATED April 15 2019 RESNICK LOUIS P C
20
21 By
22 Lisa M Bolle Esq
Attorneysfor Thornas Morton and Tracey
23
Landon
24
25
26
27
28
THOMAS MORTON TRACEY LANDON S MOTION FOR GOOD FAITH SETTLEMENT DETERMINATION
2
Document Filed Date
April 15, 2019
Case Filing Date
May 25, 2017
Category
PI Motor Vehicle
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aNA 8 1 RESNICK LOUIS P C SUPERIOR COURT flF CALIFORNIA COUN Y OF SAN BERNAFtDiNO Lisa M Bolle E sq SBN 282791 SAN BERNARDINO DISTRICT 2 9891 Irvine Center Dr Suite 200 R 1 5 2 9 Irvine CA 92618 A 3 Telephone 714 709 4400 4 714 709 4400 j Facsimile BY Email lbolle a rlattorne s MELIS5A WNITE DEPUN C 5 Attorneysfor Defendants Cross Defendants Cross Complainants Thomas Morton and Tracey Landon C 1 C 1 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 j 9 FOR THE COUNTY OF SAN BERNARDINO 10 SSIE AVALOS an individual Case No CIVDS1709871 11 Plaintiff DEFENDANTS THOMAS MORTON 12 vs AND TRACEY LANDON S NOTICE 13 OF MOTION AND MOTION FOR CHARLEY ROLLINS an individual GOOD FAITH SETTLEMENT 14 LOREA ROLLINS an individual DETERMINATION MEMORANDUIVI THOMAS MORTON an individual OF POINTS AND AUTHORITIES 15 MERLIN WILLHITE COLLTMBIA DECLARATION OF LISA BOLLE 16 STEEL INC and DOES 1 through 20 AND PROPOSED ORDER Inclusive 1 1g Defendants Action Filed May 25 2017 Trial July 15 2019 19 AND ALL RELATED CROSS ACTION 20 21 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD 22 PLEASE TAKE NOTICE that Defendants Cross Complainants Cross Defendants Thomas 23 Morton and Tracey Landon hereinafter Settlors by and through the undersigned counsel will 24 apply for an order determining the settlement entered into between Plaintiff Jessie Avalos 25 hereinafter Plaintiffl and Settlors was made in good faith pursuant to California Code of Civil 26 Procedure sections 877 and 877 6 a 2 27 Settlors and Plaintiff have settled for the Settlors limits of 100 000 00 with the policy 28 settling parties to bear their own costs and attorneys fees THOMAS MORTON TRACEY LANDON S MOTION FOR GOOD FAITH SETTLEMENT DETERMINATION 1 1 The Settlors also request an order dismissing the pending cross complaints by Merlin 2 Willhite and Columbia Steele Inc against Settlors and for an order barring any future cross 3 complaints for indemnity or contribution based on negligence comparative negligence or 4 comparative fault against the Settlors 5 Pursuant to California Rules of Court Rule 3 1382 the following pleadings will be affected 6 by the settlement 7 1 Complaint filed by Plaintiff on May 25 2017 8 2 Cross Complaint against the Settlors filed by Merlin Willhite and Columbia Steel 9 Inc on July 25 2017 10 3 Cross Complaint filed by the Settlors against Charley Rollins Lorea Rollins Merlin ll Willhite and Columbia Steel Inc on September 29 2017 12 4 Answer to Cross Complaint of Merlin Whillhite and Columbia Steel Inc filed by the 13 Settlor Thomas Morton on September 29 2017 14 5 Answer to Cross Complaint of Merlin Whillhite and Columbia Steel Inc filed by the 15 Settlor Tracey Landon on December 4 2017 16 This Application will be based on the following Memorandum of Points and Authorities the 17 Declaration of Lisa Bolle and allthe pleadings records and papers on file herein 18 19 DATED April 15 2019 RESNICK LOUIS P C 20 21 By 22 Lisa M Bolle Esq Attorneysfor Thornas Morton and Tracey 23 Landon 24 25 26 27 28 THOMAS MORTON TRACEY LANDON S MOTION FOR GOOD FAITH SETTLEMENT DETERMINATION 2