On February 26, 2019 a Answer 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 Thomas C Corless Esq SBN 100614 Max G Carpinelli SBN 286232 a x 2 WILSON ELSER MOSKOWITZ t r EDELMAN DICKER LLP A 4 vti is E Lv M 21f 3 555 South Flower Street Suite 2900 Los Angeles California 90071 d 4 Telephone 213 443 5100 Facsimile 213 443 5101 3 a 5 au t f E I Yf t t ii i i Attorneys for Defendant 6 BC STOCKING DISTRIBUTING 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 COUNTY OF SAN BERNARDINO 9 CHRISTOPHER TORRES and MELISSA Case No CIVDS1906092 10 TORRES Assigned to Hon Bryan F Foster Department S22 11 Plaintiffs 12 vs 13 DEFENDANT BC STOCKING BARNES GROUP INC as successor by DISTRIBUTING S ANSWER TO acquisition of Kar Products Inc a Delaware COMPLAINT 14 corporation BC STOCKING DISTRIBUTING a California corporation 15 CHEVRON CORPORATION a Delaware 16 corporation CRC INDUSTRIES INC doing business in California as PENNSYLVANIA 1 CRC INDUSTRIES INC a Pennsylvania corporation DAP PRODUCTS INC a Delaware corporation HUSQVARNA 1 g PROFESSIONAL PRODUCTS INC a Delaware corporation KERN OIL 19 REFINING CO a California corporation LEE DUSTRIES INC a Missouri corporation 20 MIDWEST MOTOR SUPPLY CO an Ohio Corporation NCH Corporation a Delaware 21 corporation OATEY CO an Ohio corporation PETRO SOURCE 22 INVESTMENTS INC formerly Petro Source 23 Refining Corporation a Delaware corporation PPG INDUSTRIES INC a Pennsylvania 24 corporation P T TECHNOLOGIES INC a Florida corporation QUAKER STATE 25 CORPORATION as successor by acquisition of Westland Oil Company Inc a Delaware corporation UNION OIL COMPANY OF 26 CALIFORNIA a California corporation WD 40 COMPANY a Delaware corporation and DOES 1 2 through 100 Inclusive 28 Defendants 1 DEFENDANT E3C STOCKING DISTRIBUTING S ANSWER TO COMPLAINT 3310583v 1 1 COIVIES NOW Defendant BC STOCKING DISTRIBUTING hereinafter I hi 2 Answering Defendant and in answering Plaintiffs Complaint BC STOCKIN 3 DISTRIBUTING admits denies and alleges as follows for itself alone and for no othe 4 defendant 5 GENERAL DENIAL 6 This Answering Defendant denies generally and specifically each and every allegatio 7 and cause of action in the Complaint pursuant to the provisions of California Code of Civi 8 9 Procedure Section 431 30 and denies that the plaintiffs herein has sustained injury or damage i 10 the amount alleged or in any amount or amounts or at all which were proximately caused b this Answering Defendant 11 FIRST AFFIRMATIVE DEFENSE 12 1 This Defendant Answering alleges that the Complaint and each and ever 13 purported cause of action therein fail to state facts sufficient to constitute a cause of actio 14 against this Answering Defendant 15 SECOND AFFIRMATIVE DEFENSE 16 2 This Answering Defendant alleges that if plaintiffs suffered any injuries o 17 damages plaintiffs own negligence or culpable conduct proximately caused those injuries o 18 damages 19 THIRD AFFIRMATIVE DEFENSE 20 3 This Answering Defendant alleges that if plaintiffs suffered any injuries o 21 22 damages those injuries or damages were proximately caused or contributed to by the negligenc or otherwise culpable conduct of individuals or entities other than this Answering Defendant an 23 this Answering Defendant is entitled to indemnification or contribution from these othe 24 individuals or entities 25 FOURTH AFFIRMATIVE DEFENSE 26 4 This Answering Defendant alleges that plaintiffs were capable of and failed t 27 mitigate their damages if any exist 28 2 DEFENDAN T BC STOCKING DISTRIBUTING S ANSWER TO COMPLAINT 3310583v 1