On January 22, 2019 a Request,Application was filed involving a dispute between Chulick, Carol, Hagen, Deborah, Hagler, Joleen, and Anheuser-Busch, Llc, Anheuserbusch, Llc, Associated Insulation Of California, Buttner Corp., Columbia Mechanical Contractors, Inc., Cooper Brothers, Inc., Cosco Fire Protection, Inc., Does 1 Through 800, Inclusive, As Required By, D. Zelinksy & Sons, Inc., D. Zelinsky & Sons, Incorporated, Fdcc California, Inc., Frank Bonetti Plumbing, Inc., George H. Wilson, Inc., George Wilson Company, Inc., Grinnell Llc, Grinnell Llc (Fka Grinnell Corporation, Aka, Johnson Controls, Inc., Kelly-Moore Paint Company, Inc., Kellymoore Paint Company, Inc., Marconi Plastering Company, Inc., Metropolitan Life Insurance Company, Monterey Mechanical Co., Riley Power Inc., Rosendin Electric, Inc., Rudolph And Sletten, Inc., Scott Co. Of California, Texaco Inc., W.L. Hickey Sons, Inc., Chulick, Carol, Hagen, Deborah, Hagler, Joleen, for ASBESTOS in the District Court of San Francisco County.
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1 Khaled Taqi-Eddin, Esq. SBN 220923 Emily Cunningham, Esq. SBN 303905 2 HAWKINS PARNELL & YOUNG, LLP ELECTRONICALLY One Post Street, Suite 2400 3 San Francisco, CA 94104 FILED Superior Court of California, Telephone: (415) 766-3200 County of San Francisco 4 Facsimile: (415) 766-3250 E-mail: ktaqi-eddin@hpylaw.com 09/23/2020 5 ecunningham@hpylaw.com Clerk of the Court BY: EDNALEEN ALEGRE Deputy Clerk 6 Attorneys for Intervenors MASSACHUSETTS BAY INSURANCE 7 COMPANY, MARYLAND CASUALTY COMPANY AND FIREMAN’S FUND 8 INSURANCE COMPANY 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF SAN FRANCISCO 11 12 CAROL CHULICK, as Successor-in-Interest to CGC-19-276757 and as Wrongful Death Heir of JOHN 13 CHULICK, Deceased; and DEBORAH HAGEN REQUEST FOR JUDICIAL NOTICE IN and JOLEEN HAGLER, as Wrongful Death SUPPORT OF MASSACHUSETTS BAY 14 Heirs of JOHN CHULICK, Deceased, INSURANCE COMPANY, MARYLAND CASUALTY COMPANY AND 15 Plaintiffs, FIREMAN’S FUND INSURANCE COMPANY’S EX PARTE APPLICATION 16 vs. FOR LEAVE TO FILE ANSWER-IN- INTERVENTION 17 RILEY POWER, INC., et al., 18 Defendants. Date: September 24, 2020 Time: 11:00 a.m. 19 Dept.: 503 Judge: Hon Cynthia Ming-Mei Lee 20 Action Filed: January 22, 2019 21 Trial Date: TBD 22 23 Intervenors MASSACHUSETTS BAY INSURANCE COMPANY, MARYLAND 24 CASUALTY COMPANY AND FIREMAN’S FUND INSURANCE COMPANY 25 (“INTERVENORS”) respectfully request that this Court take judicial notice, pursuant to Evidence 26 Code §§452 (c), (h) and 453, of the following documents attached hereto: 27 1. MARCONI PLASTERING COMPANY, INC. is a suspended California corporation. 28 Attached hereto as Exhibit 1 is a true and correct copy of the Business Entity Detail printout for 1 REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF MASSACHUSETTS BAY INSURANCE COMPANY, MARYLAND CASUALTY COMPANY AND FIREMAN’S FUND INSURANCE COMPANY’S EX PARTE APPLICATION FOR LEAVE TO FILE ANSWER-IN- INTERVENTION 10715603v.1 1 MARCONI PLASTERING COMPANY, INC. from the California Secretary of State website, at ., 2 dated September 23, 2020 stating that MARCONI PLASTERING COMPANY, INC.’s corporate 3 status has been suspended. 4 2. Attached hereto as Exhibit 2 is a true and correct copy of the Entity Status Letter from 5 the California Franchise Tax Board, dated September 23, 2020, stating that MARCONI 6 PLASTERING COMPANY, INC. is not in good standing with the Franchise Tax Board. 7 Dated: September 23, 2020 HAWKINS PARNELL & YOUNG LLP 8 9 By: Khaled Taqi-Eddin 10 Emily Cunningham Attorneys for Intervenors 11 MASSACHUSETTS BAY INSURANCE COMPANY, MARYLAND CASUALTY 12 COMPANY and FIREMAN’S FUND INSURANCE COMPANY 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF MASSACHUSETTS BAY INSURANCE COMPANY, MARYLAND CASUALTY COMPANY AND FIREMAN’S FUND INSURANCE COMPANY’S EX PARTE APPLICATION FOR LEAVE TO FILE ANSWER-IN- INTERVENTION 10715603v.1 EXHIBIT “1” EXHIBIT “2”