On February 26, 2019 a Motion-Secondary 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.
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1 THOMA S J TOBIN SBN 18 7062 s E ac ca rz c fic r i ttobin@grsm com cou vTY r sAiV B 2ttiR2 t 1 r f 3 cr 2 F G4RDON REES SCULLY MANSUKHANI LLP 101 W Broadway Suite 2900 UG 3 0 9 3 San Diego CA 92101 Telephone 619 696 67Q0 4 Facsimile 619 596 7124 s L F t3 f Y TY S Attarneys for Defendants KERN OIL REFINING CQ NCH CORPORATION AND LIG ITHOUSE FOR THE 6 BLIND LHB INDUSTRIES INC 8 SUPERIOR CC3URT OF CALIFC3RNIA 9 COUNTY OF SAN BERNARDINQ 10 w ll CHRISTOPHER TORRES and MELISSA CASE N CIVDS1906092 a To s 12 0 N CERTAIN DEFENDANTS AT ISSUE Plaintiffs MEMORANDUM UNDER LOCAL 1 RULE 411 1 vs v 14 Complaint Filed February 26 2019 BARNES GROUP INC as successor by o 15 acquisition of Kar Products Inc a Delaware A carporation B C STOCKING a 3 DISTR IBUTING a California carporation c o CHEVRON CORPORATION a Delaware 17 carporation GRC INDUSTRIES INC WHICH WILL D BUSINESS IN 18 CALIFCIRNIA AS PENNSYLVANIA CRC INDUSTRIES INC a Pennsylvania 19 corporation DAP PRODUCTS INC a Delaware corparation HUSQVARNA 20 PROFESSIONAL PRODUCTS INC a Delaware corporation KERN OIL 1 REFINING Ct a Califarnia eorporation LHB INDUSTRIES INC a Missouri 22 corporation MIDWEST MOTQR SUPPLY CO an Ohio corparation NCH 23 ORPORATION a Delaware carporation OATEY CO an Ohio corporation PETRO 24 SOURCE INVESTMENTS INC formerly Petro Source Refining Corporatian a 25 Delaware corporatian PFG INDUSTRIES INC a I ennsylvania corparation P T 26 TECHNOLOCIES INC a Florida carporation QUAKCR STATE 27 CORPORATIC N as successor by acquisition of Westland Oil Company Inc a Delaware 8 corporation SAFETY KLEEN SI STEMS 1 CERTAIN DEFENDANTS AT ISSUE MEMORANDUM UNDER LOCAL RULE 411 1 1 INC a Wisconsin corporation LJNION OIL COMPANY OF CALIFORNIA a California 2 corporation WD 40 COMPANY A Delaware corporation and DOES 1 through 3 100 inclusive 4 Defendants 5 6 TO THE HONORABLE COURT ALL PARTIES AND THEIR ATTORNEYS Pursuant to San Bernardino County Local Rule 411 1 Defendants KERN OIL g REFINING CO NCH Corporation and LIGHTHOUSE FOR THE BLIND LHB 9 INDUSTRIES INC Certain Defendants hereby submit the following At Issue 10 Memorandum for the upcoming August 26 2019 Trial Setting Conference 11 I BACKGROUND a a 12 This matter arises out of plaintiffs Christopher Torres and Melissa Torres claims that R N 0 fl 13 N as a result of Mr Torres alleged occupational exposure to various chemical products that v 14 were manufactured supplied and or distributed by 18 different defendants he developed o 15 Q kidney cancer which required him to under medical treatment a 3 16 II THE PLEADINGS ARE SETTLED 1 Plaintiffs commenced this action on February 26 2019 Thereafter in April of 2019 0 Ig these Certain Defendants filed their Answers to the Complaint 19 IIL STATUS OF DISCOVERY AND AUTHORIZATION 20 These Certain Defendants served written discovery on the plaintiffs in April of 2019 21 and have yet to receive responses Plaintiffs have also responded to various other defendants 22 written discovery 23 In their responses plaintiffs indicate that Mr Torres was allegedly occupationally 24 exposed to defendants products while he was employed at various federal agencies In 25 particular plaintiffs allege that Mr Torres was employed with the U S Department of the 26 Navy from approximately 1993 to 1997 the Bureau of Reclamation of the U S Department of 27 the Interior froin September 1997 to November 2008 and from March 2018 to the present day 28 and the U S Department of Forestry from approximately 2008 to March 2018 2 CERTAIN DEFENDANTS AT ISSUE MEMORANDUM UNDER LOCAL RULE 411 1