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ELECTRONICALLY
Brian C. O'Hara, Esq. (SBN: 134024) FILED
Superior Court of Catifornia,
SKEBBA, Ee Saanace County of San Francisco
ne Montgomery Street, Suite 255
San Francisco, CA_ 94104 02/06/2019
Telephone: (415) 836-2626 BY:BOWMAN LIU
Facsimile: (415) 836-3104 Deputy Clerk
Attorneys for Defendant/Cross-Complainant,
JONES LANG LASALLE AMERICAS, INC.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN FRANCISCO
MARIE DE GUZMAN,
Plaintiff,
CGC-17-561142
[Unlimited Civil]
Judge: Hon. Teri L. Jackson
v. Ctrm: 610
COLUMBIA PROPERTY TRUST:
JONES LANG LASALLE AMERICAS,
INC.; CROWN BUILDING
MAINTENANCE CO., and DOES | to 50,
APPLICATION FOR DETERMINATION
OF GOOD FAITH SETTLEMENT BY
DEFENDANT JONES LANG LASALLE
AMERICAS, INC.
(Code Civ. Proc. § 877.6(a)(2))
Defendants.
(Filed Concurrently with Notice of Settlement
of Defendant Jones Lang Lasalle Americas,
Inc.; and (Proposed) Order)
Complaint Filed: September 5, 2017
AND RELATED CROSS-ACTIONS. Se eee
Defendant JONES LANG LASALLE AMERICAS, INC. hereby applies to this Court in
accordance with the provisions of Code of Civil Procedure Section 877.6(a)(2) for a determination
that the settlement described in detail below was entered into in good faith.
1. SETTLING PARTIES:
The parties to the settlement are the Plaintiff MARIE DE GUZMAN and this Defendant
only: JONES LANG LASALLE AMERICAS, INC.
MW
-l-
APPLICATION FOR DETERMINATION OF GOOD FAITH SETTLEMENT BY DEFENDANT
JONES LANG LASALLE AMERICAS, INC.om IN DH BF wWN
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2. BASIS, TERMS AND AMOUNTS:
The basis and terms of the settlement are that Plaintiff agrees to dismiss Defendant JONES
LANG LASALLE AMERICAS, INC. only, with prejudice, in exchange for payment of the sum
of $4,000.00, with no judgment to be entered or taken Defendant JONES LANG LASALLE
AMERICAS, INC.; and each settling party to bear his/her/its own costs of expenses in this matter.
This settlement is a fair and reasonable consideration for the compromise, release and dismissal of
the claims against defendant stated herein for reasons including, but not limited to, the substantial
liability dispute and uncertainty in Plaintiff's claims against the settling Defendant.
3. LIST OF PARTIES:
The following is a list of all parties to this action:
Plaintiff: MARIE DE GUZMAN
Defendants: COLUMBIA PROPERTY TRUST;
CROWN BUILDING MAINTENANCE CO. dba ABLE BUILDING
MAINTENANCE CO.
4. PLEADINGS AFFECTED BY SETTLEMENT:
The only pleading affected by this settlement is this action. The settlement, if determined to
be in good faith, will result in the following parties remaining as defendants in this action:
* COLUMBIA PROPERTY TRUST;
« CROWN BUILDING MAINTENANCE CO. dba ABLE BUILDING
MAINTENANCE CO.
5. REQUEST FOR DISMISSAL:
Applicant JONES LANG LASALLE AMERICAS, INC. hereby requests dismissal of the
Complaint, with prejudice, as to Defendant JONES LANG LASALLE AMERICAS, INC. only.
DATED: February 6, 2019 SKEBBA, ISAAC & BUECHLER
By: kK @ Gfoe—
Brian C. O’Hara
Attorneys for Defendant/Cross-Complainant,
JONES LANG LASALLE AMERICAS,
INC.
2.
APPLICATION FOR DETERMINATION OF GOOD FAITH SETTLEMENT BY DEFENDANT
JONES LANG LASALLE AMERICAS, INC.om IN DH BF wWN
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PROOF OF SERVICE
STATE OF CALIFORNIA )
SS:
COUNTY OF ORANGE )
I, Laura Knowles, am employed in the County of Orange, State of California. I am over
the age of 18 and not a party to the within action; my business address is: One MacArthur Place,
Suite 650, Santa Ana, California 92707.
On February 6, 2019, I served the foregoing document described as follows:
1. APPLICATION FOR DETERMINATION OF GOOD FAITH SETTLEMENT BY
DEFENDANT JONES LANG LASALLE AMERICAS, INC.
2. [PROPOSED] ORDER DETERMINING GOOD FAITH SETTLEMENT
CONCERNING DEFENDANT JONES LANG LASALLE AMERICAS, INC.
The documents were served on all interested parties in said action by placing true copies thereof
enclosed in sealed envelopes addressed as follows:
SEE ATTACHED “SERVICE LIST”
Xx] BY CERTIFIED MAIL — RETURN RECEIPT REQUESTED - | am "readily
familiar" with the firm's practice of collection and processing correspondence for mailing.
Under that practice, certified mail it would be deposited with the U.S. Postal Service on
that same day with postage thereon fully prepaid at Santa Ana, California, in the ordinary
course of business.
Oo BY FAX - I sent a true copy thereof via telephone facsimile transmission to the following
number(s):
O BY PERSONAL SERVICE: On ***, I caused the above-described document to be hand
delivered to all counsel listed on the attached service list.
& (State) I declare under penalty of perjury under the laws of the State of California that the
above is true and correct. Executed on February 6, 2019, at Santa Ana, California.
Latira Knowles
3-
APPLICATION FOR DETERMINATION OF GOOD FAITH SETTLEMENT BY DEFENDANT
JONES LANG LASALLE AMERICAS, INC.om IN DH BF wWN
10
MARIE DE GUZMAN vy. COLUMBIA PROPERTY TRUST et al.
San Francisco Superior Court Case No.: CGC-17-561142
SERVICE LIST
Nikolaus W. Reed, Esq.
LAW OFFICE OF NIKOLAUS W. REED
135 10" Street
San Francisco, CA 94103
Attorney for Plaintiff, MARIE DE
GUZMAN
Tel: (415) 940-7766
Fax; (415) 940-7706
Nik@nwrlaw.com
Keith G. Bremer, Esq.
Alison K. Hurley, Esq.
Lilya Dishchyan, Esq.
BREMER WHYTE BROWN & O'MEARA
LLP
20320 S.W. Birch Street, Second Floor
Newport Beach, CA 92660
Attorney for Defendant/Cross-Defendant,
CROWN BUILDING MAINTENANCE
CO. dba ABLE BUILDING
MAINTENANCE CO.
Tel: (949) 221-1000
Fax: (949) 221-1001
kbremer@bremerwhyte.com
ahurley@bremerwhyte.com
Idishchyan@bremerwhyte.com
Debra Steel Sturmer, Esq.
Nicole A. Deterding, Esq.
LERCH STURMER LLP
One Sansome Street, Suite 2060
San Francisco, CA 94104
Attorney for Defendant/Cross-
Complainant, COLUMBIA PROPERTY
TRUST
Tel: (415) 217-6342
dsturmer@lerchsturmer.com
ndeterding@lerchsturmer.com
4.
APPLICATION FOR DETERMINATION OF GOOD FAITH SETTLEMENT BY DEFENDANT
JONES LANG LASALLE AMERICAS, INC.
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om IN DH BF wWN 10 ELECTRONICALLY Brian C. O'Hara, Esq. (SBN: 134024) FILED Superior Court of Catifornia, SKEBBA, Ee Saanace County of San Francisco ne Montgomery Street, Suite 255 San Francisco, CA_ 94104 02/06/2019 Telephone: (415) 836-2626 BY:BOWMAN LIU Facsimile: (415) 836-3104 Deputy Clerk Attorneys for Defendant/Cross-Complainant, JONES LANG LASALLE AMERICAS, INC. SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO MARIE DE GUZMAN, Plaintiff, CGC-17-561142 [Unlimited Civil] Judge: Hon. Teri L. Jackson v. Ctrm: 610 COLUMBIA PROPERTY TRUST: JONES LANG LASALLE AMERICAS, INC.; CROWN BUILDING MAINTENANCE CO., and DOES | to 50, APPLICATION FOR DETERMINATION OF GOOD FAITH SETTLEMENT BY DEFENDANT JONES LANG LASALLE AMERICAS, INC. (Code Civ. Proc. § 877.6(a)(2)) Defendants. (Filed Concurrently with Notice of Settlement of Defendant Jones Lang Lasalle Americas, Inc.; and (Proposed) Order) Complaint Filed: September 5, 2017 AND RELATED CROSS-ACTIONS. Se eee Defendant JONES LANG LASALLE AMERICAS, INC. hereby applies to this Court in accordance with the provisions of Code of Civil Procedure Section 877.6(a)(2) for a determination that the settlement described in detail below was entered into in good faith. 1. SETTLING PARTIES: The parties to the settlement are the Plaintiff MARIE DE GUZMAN and this Defendant only: JONES LANG LASALLE AMERICAS, INC. MW -l- APPLICATION FOR DETERMINATION OF GOOD FAITH SETTLEMENT BY DEFENDANT JONES LANG LASALLE AMERICAS, INC.om IN DH BF wWN 10 2. BASIS, TERMS AND AMOUNTS: The basis and terms of the settlement are that Plaintiff agrees to dismiss Defendant JONES LANG LASALLE AMERICAS, INC. only, with prejudice, in exchange for payment of the sum of $4,000.00, with no judgment to be entered or taken Defendant JONES LANG LASALLE AMERICAS, INC.; and each settling party to bear his/her/its own costs of expenses in this matter. This settlement is a fair and reasonable consideration for the compromise, release and dismissal of the claims against defendant stated herein for reasons including, but not limited to, the substantial liability dispute and uncertainty in Plaintiff's claims against the settling Defendant. 3. LIST OF PARTIES: The following is a list of all parties to this action: Plaintiff: MARIE DE GUZMAN Defendants: COLUMBIA PROPERTY TRUST; CROWN BUILDING MAINTENANCE CO. dba ABLE BUILDING MAINTENANCE CO. 4. PLEADINGS AFFECTED BY SETTLEMENT: The only pleading affected by this settlement is this action. The settlement, if determined to be in good faith, will result in the following parties remaining as defendants in this action: * COLUMBIA PROPERTY TRUST; « CROWN BUILDING MAINTENANCE CO. dba ABLE BUILDING MAINTENANCE CO. 5. REQUEST FOR DISMISSAL: Applicant JONES LANG LASALLE AMERICAS, INC. hereby requests dismissal of the Complaint, with prejudice, as to Defendant JONES LANG LASALLE AMERICAS, INC. only. DATED: February 6, 2019 SKEBBA, ISAAC & BUECHLER By: kK @ Gfoe— Brian C. O’Hara Attorneys for Defendant/Cross-Complainant, JONES LANG LASALLE AMERICAS, INC. 2. APPLICATION FOR DETERMINATION OF GOOD FAITH SETTLEMENT BY DEFENDANT JONES LANG LASALLE AMERICAS, INC.om IN DH BF wWN 10 PROOF OF SERVICE STATE OF CALIFORNIA ) SS: COUNTY OF ORANGE ) I, Laura Knowles, am employed in the County of Orange, State of California. I am over the age of 18 and not a party to the within action; my business address is: One MacArthur Place, Suite 650, Santa Ana, California 92707. On February 6, 2019, I served the foregoing document described as follows: 1. APPLICATION FOR DETERMINATION OF GOOD FAITH SETTLEMENT BY DEFENDANT JONES LANG LASALLE AMERICAS, INC. 2. [PROPOSED] ORDER DETERMINING GOOD FAITH SETTLEMENT CONCERNING DEFENDANT JONES LANG LASALLE AMERICAS, INC. The documents were served on all interested parties in said action by placing true copies thereof enclosed in sealed envelopes addressed as follows: SEE ATTACHED “SERVICE LIST” Xx] BY CERTIFIED MAIL — RETURN RECEIPT REQUESTED - | am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice, certified mail it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid at Santa Ana, California, in the ordinary course of business. Oo BY FAX - I sent a true copy thereof via telephone facsimile transmission to the following number(s): O BY PERSONAL SERVICE: On ***, I caused the above-described document to be hand delivered to all counsel listed on the attached service list. & (State) I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on February 6, 2019, at Santa Ana, California. Latira Knowles 3- APPLICATION FOR DETERMINATION OF GOOD FAITH SETTLEMENT BY DEFENDANT JONES LANG LASALLE AMERICAS, INC.om IN DH BF wWN 10 MARIE DE GUZMAN vy. COLUMBIA PROPERTY TRUST et al. San Francisco Superior Court Case No.: CGC-17-561142 SERVICE LIST Nikolaus W. Reed, Esq. LAW OFFICE OF NIKOLAUS W. REED 135 10" Street San Francisco, CA 94103 Attorney for Plaintiff, MARIE DE GUZMAN Tel: (415) 940-7766 Fax; (415) 940-7706 Nik@nwrlaw.com Keith G. Bremer, Esq. Alison K. Hurley, Esq. Lilya Dishchyan, Esq. BREMER WHYTE BROWN & O'MEARA LLP 20320 S.W. Birch Street, Second Floor Newport Beach, CA 92660 Attorney for Defendant/Cross-Defendant, CROWN BUILDING MAINTENANCE CO. dba ABLE BUILDING MAINTENANCE CO. Tel: (949) 221-1000 Fax: (949) 221-1001 kbremer@bremerwhyte.com ahurley@bremerwhyte.com Idishchyan@bremerwhyte.com Debra Steel Sturmer, Esq. Nicole A. Deterding, Esq. LERCH STURMER LLP One Sansome Street, Suite 2060 San Francisco, CA 94104 Attorney for Defendant/Cross- Complainant, COLUMBIA PROPERTY TRUST Tel: (415) 217-6342 dsturmer@lerchsturmer.com ndeterding@lerchsturmer.com 4. APPLICATION FOR DETERMINATION OF GOOD FAITH SETTLEMENT BY DEFENDANT JONES LANG LASALLE AMERICAS, INC.