Request,Application: ELLIOTT GALYNSKY, ET AL. VS JUAN ANTONIO PAIZ, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 12/07/2021 03:26 PM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Soto,Deputy Clerk


                  1     Doug Griffith, Esq. (State Bar No. 185333)
                        Email: dgriffith@victorrane.com
                  2     VICTOR RANE
                        9350 Wilshire Blvd., Suite 308
                  3     Beverly Hills, California 90212
                        Telephone: (818) 919-8541
                  4     Facsimile: (213) 814-4530

                  5     Attorneys for Defendant
                        KPS AIRMOTIVE INC.
                  6

                  7

                  8                                   SUPERIOR COURT OF THE STATE OF CALIFORNIA

                  9                                               FOR THE COUNTY OF LOS ANGELES

                10
                        ELLIOTT GALYNSKY, et al.,                                                  )     Case No.: 20STCV33006
                11                                                                                 )
                                               Plaintiffs,                                         )     [Assigned for all purposes to the Hon.
                12                                                                                 )     Barbara A. Meiers, Dept. 12]
                                    vs.                                                            )
                13                                                                                 )     DEFENDANT KPS AIRMOTIVE INC.’S
                        JUAN ANTONIO PAIZ, et al.,                                                 )     APPLICATION FOR GOOD FAITH
                14                                                                                 )     SETTLEMENT DETERMINATION;
                                    Defendant.                                                     )
                15                                                                                 )     DECLARATION OF DOUG GRIFFITH,
                        ____________________________________
                                                                                                   )     ESQ. IN SUPPORT
                16      AND RELATED CROSS-ACTIONS                                                  )
                                                                                                   )      [CCP § 877.6(a)(2)]
                17                                                                                 )
                                                                                                   )     Complaint filed:                  August 28, 2020
                18                                                                                 )     Trial date:                       July 18, 2022
                                                                                                   )
                19                                                                                 )
                                                                                                   )
                20

                21      I.          INTRODUCTION
                22                  As set forth below, a settlement agreement (“Settlement”) has been reached
                23      between Plaintiffs and defendant KPS Airmotive Inc. (“KPS”) arising out of the August
                24      29, 2018 airplane accident giving rise to the action.
                25

                26      II.         TERMS OF SETTLEMENT
                27                  The Settlement is between Plaintiffs, collectively, and KPS, and calls for
                28      Plaintiffs’ dismissal with prejudice of their complaint in the within action, filed on
                        DEFENDANT KPS AIRMOTIVE, INC.’S NOTICE OF
                        SETTLEMENT AND APPLICATION FOR GOOD FAITH
                        SETTLEMENT ORDER
                        CASE NO.: 20STCV33006