On February 26, 2019 a
Party Notice
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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COUNEY 0F SAN BERNARDINQ
THOMAS J. TOBIN (SBN: 187062) SAN FRNARWNO WSTWCT
ttobin@grsm.com
GORDON REES SCULLY MANSUKHANI, LLP
101W. Broadway, Suite 2000
San Diego, CA 92101
UI$UJN
Telephone: (6 1 9) 696-6700
Attorneys for Defendant
LIGHTHOUSE FOR THE BLIND (LHB INDUSTRIES, INC.)
\DOOQON
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
10
11 CHRISTOPHER TORRES and MELISSA CASE NO. CIVDSl906092
LLP
TORRES,
2000
12 DEFENDANT LIGHTHOUSE FOR
Plaintiffs, THE BLIND’S (LHB INDUSTRIES,
13 INC.) NOTICE OF SETTLEMENT
Mansukhani,
92101
Syite
vs.
CA 14
Scully
Broadway, BARNES GROUP INC, as successor by Complaint Filed: February 26, 2019
Diego,
15 acquisition of Kar Products, Inc., a Delaware
corporation; B C STOCKING
Rees
W. San
16 DISTRIBUTING, a California corporation;
101 CHEVRON CORPORATION, a Delaware
Gordon
17 CRC INDUSTRIES, INC.
corporation;
WHICH WILL DO BUSINESS IN
18 CALIFORNIA AS PENNSYLVANIA CRC
INDUSTRIES, INC., a Pennsylvania
19 corporation; DAP PRODUCTS, INC, a
HUSQVARNA
VVVVVVVVVVVVVVVVVVVVVVVVVVVvvvv
Delaware corporation;
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
0f Westland Oil Company, Inc. a Delaware
28
-1-
DEFENDANT LIGHTHOUSE FOR THE BLIND’S (LHB INDUSTRIES, INC.)
NOTICE OF SETTLEMENT
corporation; SAFETY-KLEEN SYSTEMS,
INC., a Wisconsin corporation; UNION OIL
COMPANY OF CALIFORNIA, a California
corporation; WD-40 COMPANY, A
Delaware corporation; and DOES 1 through
UI-PUJN
100, inclusive,
Defendants.
TO THE HONORABLE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF
\OWNON
RECORD:
PLEASE TAKE NOTICE that Defendant LIGHTHOUSE FOR THE BLIND (LHB
Industries, Inc.) (“Defendant”) has entered into a settlement with Plaintiffs CHRISTOPHER
10
TORRES and MELISSA TORRES (“Plaintiffs”), in the amount of $10,000.00, subject to a
11
LLP
determination 0f good faith settlement, pursuant t0 California Code of Civil Procedure section
2000
12
877.6(a)(2). A copy of the Application, Declaration of Thomas J. Tobin, and proposed Order are
Mansukhani,
Syite
92101 13
attached hereto and are filed and served herewith by certified mail.
CA 14
Scully
Broadway,
Diego,
PLEASE TAKE FURTHER NOTICE that LIGHTHOUSE FOR THE BLIND (LHB
15
Industries, Inc.) submits the attached Application, served and filed concurrently herewith,
Rees
W. San
16
101 pursuant to California Code of Civil Procedure section 877.6(a)(2) for a judicial determination
Gordon
17
that the settlement with Plaintiffs is made in good faith and for an order that LIGHTHOUSE
18
FOR THE BLIND (LHB Industries, Inc.) be discharged from any and all liability for any claims
19
arising out 0f this action including any claims for equitable contribution, comparative
20
contribution, partial indemnity, comparative indemnity, comparative negligence or comparative
21
fault as it relates to this action and that any future claims brought against LIGHTHOUSE FOR
22
THE BLIND (LHB Industries, Inc.) for equitable indemnity, total indemnity 0r implied
23
contractual indemnity as related to the above—captioned action be barred and t0 the extent
24
pending, dismissed.
25
Within 25 days 0f the mailing of the Notice, Application, and Proposed Order, a non-
26
settling party must file a notice 0f motion to contest the good faith 0f this settlement should the
27
good faith of the settlement be contested. The notice by a non—settling party shall be given in the
28
-2-
DEFENDANT LIGHTHOUSE FOR THE BLIND’S (LHB INDUSTRIES, INC.)
NOTICE OF SETTLEMENT
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" fl, r, ‘ ‘M H r , “h g H‘ \ ML)“ ‘ L“ q .25““ ‘\\:\j\,’.-:m K RV“ x: -,‘1 ' SUEELbnEco‘Bm COUNEY 0F SAN BERNARDINQ THOMAS J. TOBIN (SBN: 187062) SAN FRNARWNO WSTWCT ttobin@grsm.com GORDON REES SCULLY MANSUKHANI, LLP 101W. Broadway, Suite 2000 San Diego, CA 92101 UI$UJN Telephone: (6 1 9) 696-6700 Attorneys for Defendant LIGHTHOUSE FOR THE BLIND (LHB INDUSTRIES, INC.) \DOOQON SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO 10 11 CHRISTOPHER TORRES and MELISSA CASE NO. CIVDSl906092 LLP TORRES, 2000 12 DEFENDANT LIGHTHOUSE FOR Plaintiffs, THE BLIND’S (LHB INDUSTRIES, 13 INC.) NOTICE OF SETTLEMENT Mansukhani, 92101 Syite vs. CA 14 Scully Broadway, BARNES GROUP INC, as successor by Complaint Filed: February 26, 2019 Diego, 15 acquisition of Kar Products, Inc., a Delaware corporation; B C STOCKING Rees W. San 16 DISTRIBUTING, a California corporation; 101 CHEVRON CORPORATION, a Delaware Gordon 17 CRC INDUSTRIES, INC. corporation; WHICH WILL DO BUSINESS IN 18 CALIFORNIA AS PENNSYLVANIA CRC INDUSTRIES, INC., a Pennsylvania 19 corporation; DAP PRODUCTS, INC, a HUSQVARNA VVVVVVVVVVVVVVVVVVVVVVVVVVVvvvv Delaware corporation; 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 0f Westland Oil Company, Inc. a Delaware 28 -1- DEFENDANT LIGHTHOUSE FOR THE BLIND’S (LHB INDUSTRIES, INC.) NOTICE OF SETTLEMENT corporation; SAFETY-KLEEN SYSTEMS, INC., a Wisconsin corporation; UNION OIL COMPANY OF CALIFORNIA, a California corporation; WD-40 COMPANY, A Delaware corporation; and DOES 1 through UI-PUJN 100, inclusive, Defendants. TO THE HONORABLE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF \OWNON RECORD: PLEASE TAKE NOTICE that Defendant LIGHTHOUSE FOR THE BLIND (LHB Industries, Inc.) (“Defendant”) has entered into a settlement with Plaintiffs CHRISTOPHER 10 TORRES and MELISSA TORRES (“Plaintiffs”), in the amount of $10,000.00, subject to a 11 LLP determination 0f good faith settlement, pursuant t0 California Code of Civil Procedure section 2000 12 877.6(a)(2). A copy of the Application, Declaration of Thomas J. Tobin, and proposed Order are Mansukhani, Syite 92101 13 attached hereto and are filed and served herewith by certified mail. CA 14 Scully Broadway, Diego, PLEASE TAKE FURTHER NOTICE that LIGHTHOUSE FOR THE BLIND (LHB 15 Industries, Inc.) submits the attached Application, served and filed concurrently herewith, Rees W. San 16 101 pursuant to California Code of Civil Procedure section 877.6(a)(2) for a judicial determination Gordon 17 that the settlement with Plaintiffs is made in good faith and for an order that LIGHTHOUSE 18 FOR THE BLIND (LHB Industries, Inc.) be discharged from any and all liability for any claims 19 arising out 0f this action including any claims for equitable contribution, comparative 20 contribution, partial indemnity, comparative indemnity, comparative negligence or comparative 21 fault as it relates to this action and that any future claims brought against LIGHTHOUSE FOR 22 THE BLIND (LHB Industries, Inc.) for equitable indemnity, total indemnity 0r implied 23 contractual indemnity as related to the above—captioned action be barred and t0 the extent 24 pending, dismissed. 25 Within 25 days 0f the mailing of the Notice, Application, and Proposed Order, a non- 26 settling party must file a notice 0f motion to contest the good faith 0f this settlement should the 27 good faith of the settlement be contested. The notice by a non—settling party shall be given in the 28 -2- DEFENDANT LIGHTHOUSE FOR THE BLIND’S (LHB INDUSTRIES, INC.) NOTICE OF SETTLEMENT