On April 19, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
State Farm General Insurance Company,
and
Air Vent Inc.,
Does 1-20,
for Other non-PI/PD/WD Tort Unlimited
in the District Court of San Bernardino County.
Preview
Keith E. Smith (State Bar No. 244505)
kesmith@wshblaw.com F LE I D
Courtney Jakofsky (State Bar No. 31 1368) COUNTSYUSEFggg
SAN BERNARDHNQ DISTRICT
Eggfignomo
cjakofsky@wshblaw.com
U.)
WOOD, SMITH, HENNING & BERMAN LLP
21 804 Cactus Avenue, Suite 200
JAN 1 9 2022
Riverside, California 925 ] 8-301 0
Phone: 951 779 5000 O Fax: 951 755 1650 BY
SANDRA ORTEG DEPUTY
Attorneys for Defendant, AIR VENT, INC.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
\OOQVO‘N
COUNTY OF SAN BERNARDINO
10 STATE FARM GENERAL INSURANCE Case No. CIVSB21 1 1551
COMPANY,
LLP
11 DEFENDANT AIR VENT, INC.'S NOTICE
1650
Plaintiff, OF MOTION AND MOTION FOR LEAVE
200
755
12 TO FILE CROSS COMPLAINT
BERMAN
92518-3010
v.
SUITE
951
13 Date: March 7, 2022 j
& Law
at AVENUE,
FAX
O
AIR VENT, INC. and DOES 1-20, Time: 9:00 AM
HENNING
CALIFORNIA
5000
14 INCLUSIVE, Dept. 829
Attorneys
779
CACTUS 15 Defendant. [Assigned for All Purposes to Judge Hon.
951
SMITH, Janet Frangie, Dept. $29]
RIVERSIDE,
21804 16
TELEPHONE
Action Filed: April 19, 2021
WOOD,
17 Trial Date: None Set
18
t
1’00
‘ _ ‘
O Z} ,.
a: ~52 L29
l
X 3
5? ~//\( >57
19 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
20 PLEASE TAKE NOTICE that on March 7, 2022 at 9:00 a.m. in Department $29 0f the
21 above-entitled court located at 247 West Third Street, San Bemardino, California, before the
22 Honorable Judge Janet Frangie, Defendant AIR VENT, INC. (hereinafter, "Defendant"), will move
23 the Court for an Order permitting Defendant to file a Cross-Complaint in accordance with California
24 Code ofCivil Procedure §§ 428.10, 428.50, and 426.50. This motion is made on the grounds that
25 the proposed Cross-Complaint arises out of the same transaction or occurrence as does the
26 underlying Complaint. This motion is further made in good faith on the grounds that facts
27 comprising the basis for a Cross-Complaint have come to the attention of Defendant subsequent to
28 the filing 0f Defendant’s Answer, that allowing the Cross—Complaint is in the interest ofjustice, that
23274491.1:11967-0005 -1- Case No. CIVSBZI 1 1551
DEFENDANT AIR VENT, INC.'S NOTICE OF MOTION AND MOTION FOR LEAVE TO FILE CROSS
COMPLAINT
Document Filed Date
January 19, 2022
Case Filing Date
April 19, 2021
Category
Other non-PI/PD/WD Tort Unlimited
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Keith E. Smith (State Bar No. 244505) kesmith@wshblaw.com F LE I D Courtney Jakofsky (State Bar No. 31 1368) COUNTSYUSEFggg SAN BERNARDHNQ DISTRICT Eggfignomo cjakofsky@wshblaw.com U.) WOOD, SMITH, HENNING & BERMAN LLP 21 804 Cactus Avenue, Suite 200 JAN 1 9 2022 Riverside, California 925 ] 8-301 0 Phone: 951 779 5000 O Fax: 951 755 1650 BY SANDRA ORTEG DEPUTY Attorneys for Defendant, AIR VENT, INC. SUPERIOR COURT OF THE STATE OF CALIFORNIA \OOQVO‘N COUNTY OF SAN BERNARDINO 10 STATE FARM GENERAL INSURANCE Case No. CIVSB21 1 1551 COMPANY, LLP 11 DEFENDANT AIR VENT, INC.'S NOTICE 1650 Plaintiff, OF MOTION AND MOTION FOR LEAVE 200 755 12 TO FILE CROSS COMPLAINT BERMAN 92518-3010 v. SUITE 951 13 Date: March 7, 2022 j & Law at AVENUE, FAX O AIR VENT, INC. and DOES 1-20, Time: 9:00 AM HENNING CALIFORNIA 5000 14 INCLUSIVE, Dept. 829 Attorneys 779 CACTUS 15 Defendant. [Assigned for All Purposes to Judge Hon. 951 SMITH, Janet Frangie, Dept. $29] RIVERSIDE, 21804 16 TELEPHONE Action Filed: April 19, 2021 WOOD, 17 Trial Date: None Set 18 t 1’00 ‘ _ ‘ O Z} ,. a: ~52 L29 l X 3 5? ~//\( >57 19 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 20 PLEASE TAKE NOTICE that on March 7, 2022 at 9:00 a.m. in Department $29 0f the 21 above-entitled court located at 247 West Third Street, San Bemardino, California, before the 22 Honorable Judge Janet Frangie, Defendant AIR VENT, INC. (hereinafter, "Defendant"), will move 23 the Court for an Order permitting Defendant to file a Cross-Complaint in accordance with California 24 Code ofCivil Procedure §§ 428.10, 428.50, and 426.50. This motion is made on the grounds that 25 the proposed Cross-Complaint arises out of the same transaction or occurrence as does the 26 underlying Complaint. This motion is further made in good faith on the grounds that facts 27 comprising the basis for a Cross-Complaint have come to the attention of Defendant subsequent to 28 the filing 0f Defendant’s Answer, that allowing the Cross—Complaint is in the interest ofjustice, that 23274491.1:11967-0005 -1- Case No. CIVSBZI 1 1551 DEFENDANT AIR VENT, INC.'S NOTICE OF MOTION AND MOTION FOR LEAVE TO FILE CROSS COMPLAINT