On February 26, 2019 a Hearing was filed involving a dispute between Torres, Christopher, Torres, Melissa, and Barnes Group Inc., As Successor By Acquisition Of Kar Products, Inc., A, Barnes Group Inc. As Successor By Acquisition Of Kar Products,Llc, B C Stocking Distributing, A California Corporation, B'Laster Llc, Chevron Corporation, A Delaware Corporation, Chevron U.S.A. Inc, Chevron U.S.A. Inc., Crc Industries, Inc. Which Will Do Businessin California As Pennsylvania Crc Industrie, Dap Products Inc., A Delaware Corporation, Does 3-100, Husqvarna Professional Products, Inc., A Delaware Corporation, Kern Oil & Refining Co., A California Corporation, Lighthouse For The Blind, Midwest Motor Supply Co., An Ohio Corporation, Nch Corporation, A Delaware Corporation, Oatey Co., An Ohio Corporation, Pennzoil-Quaker State Company, Petro Source Investments, Inc. A Delaware Corporation, Ppg Industries, Inc. A Pennsylvania Corporation, P-T Technologies, Inc., A Florida Corporation, Quaker State Corporation, As Successor By Acquistion Of Westland Oil Company, Inc., A, Safety-Kleen Systems, Inc., A Wisconsin Corporation, Union Oil Company Of California, A California Corporation, Wd-40 Company, A Delaware Corporation, for Product Liability Unlimited in the District Court of San Bernardino County.
For full print and download access, please subscribe at https://www.trellis.law/.
Please wait a moment while we load this page.
Preview
ILED ERIOR COURT OF CALIFOR COUN fY OF SAN BERNARDl f i SAN BERNARDINO DISTRIC JUN 13 2019 1 THOMAS J TOBIN SBN 187062 ttobin@grsm com 2 GORDON REES SCULLY MANSUKHANI LLP 101W Broadway Suite 2000 1 ti 1l q 3 San Diego CA 92101 Telephone 619 696 6700 4 Attorney for Defendants 5 LIGHTHOUSE FOR THE BL1ND LHB 1NDUSTRIES INC NCH CORPORATION and KERN OIL REFINING CO 6 7 8 SUPERIOR COURT OF CALIFORNIA r I 9 COUNTY OF SAN BERNARDINO 10 z a i 11 CHRISTOPHER TORRES and MELISSA CASE NO CIVDS 1906092 TORRES 12 DEFENDANTS LIGHTHOUSE FOR 0 s Plaintiffs THE BLIND AND KERN OIL o 13 REFINING CO S OPPOSITION TO vs PLAINTIFFS MOTION FOR v 14 PROTECTIVE ORDER AND CASE o BARNES GROUP INC as successor by MANAGEMENT ORDER o 15 acquisition of Kar Products Inc a Delaware REQUIRING JOINT DISCOVERY corporation B C STOCKING a 3 16 DISTRIBUTING a California corporation Complaint Filed February 26 2019 CHEVRON CORPORATION a Delaware 0 o 17 corporation CRC INDUSTRIES INC Date June 26 2019 o WHICH WILL DO BUSINESS IN Time 8 30 a m 18 CALIFORNIA AS PENNSYLVANIA CRC Dept S22 INDUSTRIES INC a Pennsylvania 19 corporation DAP PRODUCTS INC a Delaware corporation HUSQVARNA 20 PROFESSIONAL PRODUCTS INC a Delaware corporation KERN OIL 21 REFINING CO a California corporation LHB INDUSTRIES INC a Missouri 22 corporation MIDWEST MOTOR SUPPLY CO an Ohio corporation NCH 23 CORPORATION a Delaware corporation OATEY CO an Ohio corporation PETRO 24 SOURCE INVESTMENTS INC formerly Petro Source Refining Corporation a 25 Delaware corporation PPG INDUSTRIES INC a Pennsylvania corporation P T 26 TECHNOLOGIES INC a Florida corporation QUAKER STATE 27 CORPORATION as successor by acquisition of Westland Oil Company Inc a Delaware 28 1 DEFS LIGHTHOUSE FOR THE BLIND AND KERN OIL REFINING CO S OPPOSITION TO PLNTFFS MOTION FOR PROTECTIVE ORDER AND CMO REQUIRING JOINT DISCOVERY 1 corporation SAFETY KLEEN SYSTEMS INC a Wisconsin corporation LJNION OIL 2 COMPANY OF CALIFORNIA a California corporation WD 40 COMPANY A 3 Delaware corporation and DOES 1 through 100 inclusive 4 Defendants 5 6 TO PLAINTIFFS AND THEIR COUNSEL OF RECORD 7 Defendants LIGHTHOUSE FOR THE BLIND LHB INDUSTRIES NCH 8 CORPORATION and KERN OIL REFINING CO collectively Defendants respectfully 9 submit the following opposition to Plaintiffs Motion for Protective Order Defendants also 10 incorporate by reference the arguments Defendants Union Oil and Chevron included in their Q 11 a opposition to Plaintiffs Motion In order to minimize the use of court resources on this o 12 o motion Defendants will keep this opposition brief 13 R Q Defendants simply request that Plaintiffs respond to pending discovery propounded a U 14 15 within the provisions of the Code of Civil Procedure discovery that has been routinely u o d Q propounded and responded to by other plaintiffs represented by this same firm over the past 3 16 o two decades Compelling the defendants to re configure written discovery for these particular l L v plaintiffs will take more time than simply having plaintiff respond to the straightforwatt d 18 19 discovery Defendants propounded In previous matters plaintiffs have routinely responded jointly to Form Interrogatories to which Defendants have no objection As for the special 20 interrogatories and requests for production the sets that Defendants propounded were 21 designed to elicit the specific exposure allegations to the particular products alleged against 22 each Defendant As indicated in Plaintiffs Motion and Supporting Declaration in addition to 23 24 Form Interrogatories Defendants filing this opposition served 16 special interrogatories and 23 requests for production each These amounts are less than authorized by the Code of Civil 25 26 Procedure and have been routinely been responded to by this same firm in dozens of other matters Consequently since this matter is not designated as complex and these are 27 28 interrogatories and requests for production routinely propounded and responded to in previous 2 DEFS LIGHTHOUSE FOR THE BLIND AND KERN OIL REFINING CO S OPPOSITION TO PLNTFFS MOTION FOR PROTECTIVE ORDER AND CMO REQUIRING JOINT DISCOVERY