On February 26, 2019 a Motion,Ex Parte 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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Edward Patrick Swan, Jr. (State Bar No. 89429) stanm ioncsday.c0m JONES DAY 4655 Executive Drive, Suite 1500 h Leu‘ 5a“ Dicgoa CA 92 21 I summon countgsecwpomm Tclcphonc: 858.314.1200 COUWOFSAN RNMDONO 5"" 35“"‘“°‘"° 0'9"” Facsimile: 844.345.3178 Stefanie Warren (SBN 244038) JUL 28 2023 swarrcnfu trailslawgroupxom - LAW GROUP TRAILS 3 70 Fourth Avenue, Suite 250 1 . BY' ‘ 8‘ I é Pm fi{KIEIE Way .N U ' San Diego, California 92103 Telephone: 619.501.4750 Attorneys for Defendant Petro Source Investments, Inc. (formerly Petro Source Refining Corporation) 10 SUPERIOR COURT OF THE STATE 0F CALIFORNIA ll COUNTY OF SAN BERNARDINO 12 CHRISTOPHER TORRES and MELISSA CASE N0. CIVDS1906092 TORRES, 13 Assigned for all purposes to Plaintiff, Judge David E. Driscoll, Dept. 822 l4 v. DEFENDANT PETRO SOURCE 15 INVESTMENTS, INC.’S NOTICE OF BARNES GROUP, INC. et al.. MOTION T0 JOIN AND JOINDER IN l6 DEFENDANT SAFETY-KLEEN Defendants. SYSTEMS, lNC.’S NOTICE 0F l7 MOTION AND MOTION TO BIFURCATE THE DETERMINATION l8 OF LIABILITY FROM THE DETERMINATION OF THE AMOUNT 19 OF PUNITIVE DAMAGES 20 Date: September 14, 2023 Time: 8:30 a.m. 21 Dept: 5-22 22 Complaint Filed: February 26, 2019 Trial Date: September 18, 2023 23 24 TO ALL PARTIES AND THEIR ATTORNEYS 0F RECORD: 25 PLEASE TAKE NOTICE that Defendant Petro Source Investments. Inc. (“Petro 26 Source") hcrcby movcs to join and docs join in Defendant Safcty-chcn Systems, Inc.’s (“Safety- 27 Kleen") Notice 0f Motion and Motion to Bifurcate the Determination of Liability From the 28 Determination ofthe Amount of Punitive Damages (“Motion”) filed on July 26, 2023. NAl-1537562187vl PETRO SOURCES’ NOTICE OF MOTION TO JOIN AND JOINDER IN SAFETY-KLEEN’S MOTION TO BIFURCATE Petro Source‘s joinder is based on this Notice of Motion and Motion and Defendant Safety-Kleen’s moving papers in support 0f its Motion. MEMORANDUM OF POINTS AND AUTHORITIES Petro Source’s motion to join in Safety-Kleen’s Motion is based on the fact that the arguments raised in Safety-Kleen‘s Motion are equally applicable to Petro Source, and they are incorporated herein by rcfcrcncc as if fully set forth. Pctro Source expressly reserves its rights to participate in oral argument at the time of the hearing on the motion, and t0 pursue the relief requested by thc motion ifthc moving party settles or is dismissed before the motion is determined by this Court. 10 Petro Source respectfully requests that its motion for joindcr in Safety-Kleen’s Motion be l] granted. and that the Court grant Safery-Kleen’s Motion. 12 DATED: July 28. 2023 JONES DAY 13 l4 15 By: / /Z’-« g E ward Patrick Swan, Jr. (SBN 8 429) pswaanijoncsdaycom 16 4655 Executive Drive. Suite 1500 San Diego, CA 92121-3134 Telephone: 858.314.1200 l7 Facsimile: 844.345.3178 l8 StefanieWarren (SBN 244038) 19 swarren@trailslawgroup.com TRAILS LAW GROUP 20 3 70 Fourth Avenue, Suite 250 l San Diego, Califomia 92103 21 Telephone: 619.501.4750 22 Attorneys for Defendant Petro Source Investments. Inc. 23 (formerly Petro Source Refining Corporation) 24 25 26 27 28 2 PETRO SOURCES” NOTICE OF MOTION T0 JOIN AND JOINDER IN SAFETY-KLEEN‘S MOTION TO BIFURCATE