On June 11, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
Duke Realty Limited Partnership,
Insurance Company Of The West,
Madrigal, Adriana Quintero,
Marquez, Rafael Carvajal,
and
Does 2-100,
Duke Realty Corporation,
Duke Realty Limited Partnership,
Genie Industries, Inc.,
Gregg Electric, Inc.,
I.E. General Engineering Inc.,
King Equipment, Llc,
Terex Corporation,
General Engineering, Inc,
Gregg Electric, Inc., I.E.,
King Equipment, Inc.,
Roes 2 To 100,
for Personal Injury Non-Motor Vehicle Unlimited
in the District Court of San Bernardino County.
Preview
fl
V QRMNAL
David J. Byassee, Bar No. 244509
James Whitemyer, Bar N0. 185528
PLAIN LEGAL PC
2005 Via Vina
U)
San Clemente, California 92673
(866) 286-5002
service@plain-legal.com
Attorneys for Defendant/Cross—Defendant
KING EQUIPMENT, LLC. (DOE 1)
\DOOVON
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
GE'WB
10
11 RAFAEL CARVAJAL MARQUEZ; Case No. CIVDSZO] O3 1 0
ADRIANA QUINTERO MADRIGAL,
12 DEFENDANT KING EQUIPMENT LLC’S
Plaintiffs, NOTICE OF MOTION AND MOTION
13 FOR SUMMARY JUDGMENT AS TO
v. PLAINTIFFS' COMPLAINT
14
GENIE INDUSTRIES, INC.; TEREX [Filed concurrently with Memorandum of Points and
15 CORPORATION; DUKE REALTY Authorities; Separate Statement of Undisputed
LIMITED PARTNERSHIP; DUKE Material Facts; Declaration Ernest William Quijada;
16 REALTY CORPORATION; GREGG Declaration of Attorney James Whitemyer; Index
ELECTRIC, INC.; I.E. GENERAL and Compendium of Exhibits; and Proposed Order]
17 ENGINEERING INC.; and DOES 1-100,
inclusive Motion Date: August 28, 2023
18 Time: 8:30 a.m.
Defendants. Dept: $23
19 Judge: Hon. Donald Alvarez
20 AND RELATED CROSS-ACTION(S) Action Filed: June 11, 2020
Trial Date: October 9, 2023
21
22
23 PLEASE TAKE NOTICE that on August 28, 2023, at 8:30 a.m. or as soon thereafter as
24 the matter may be heard before the Honorable Donald Alvarez in Department 23 ofthe California
25 Superior Court for the County of San Bernardino located at 247 West Third Street, San
26 Bemardino, California 92415, Defendant KING EQUIPMENT LLC (DOE 1) (“King” herein) will
27 and hereby move this Court for an Order Granting Summary Judgment in favor 0f King and
28 against Plaintiffs RAFAEL CARVAJAL MARQUEZ (“Marquez” herein) and his wife
1
DEFENDANT KING EQUIPMENT LLC’S NOTICE OF MOTION AND M
OTION FOR SUMNIARY JUDGMENT AS TO PLAINTIFFS' COMPLAINT
‘_
k
x
Document Filed Date
June 12, 2023
Case Filing Date
June 11, 2020
Category
Personal Injury Non-Motor Vehicle Unlimited
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Preview
fl V QRMNAL David J. Byassee, Bar No. 244509 James Whitemyer, Bar N0. 185528 PLAIN LEGAL PC 2005 Via Vina U) San Clemente, California 92673 (866) 286-5002 service@plain-legal.com Attorneys for Defendant/Cross—Defendant KING EQUIPMENT, LLC. (DOE 1) \DOOVON SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO GE'WB 10 11 RAFAEL CARVAJAL MARQUEZ; Case No. CIVDSZO] O3 1 0 ADRIANA QUINTERO MADRIGAL, 12 DEFENDANT KING EQUIPMENT LLC’S Plaintiffs, NOTICE OF MOTION AND MOTION 13 FOR SUMMARY JUDGMENT AS TO v. PLAINTIFFS' COMPLAINT 14 GENIE INDUSTRIES, INC.; TEREX [Filed concurrently with Memorandum of Points and 15 CORPORATION; DUKE REALTY Authorities; Separate Statement of Undisputed LIMITED PARTNERSHIP; DUKE Material Facts; Declaration Ernest William Quijada; 16 REALTY CORPORATION; GREGG Declaration of Attorney James Whitemyer; Index ELECTRIC, INC.; I.E. GENERAL and Compendium of Exhibits; and Proposed Order] 17 ENGINEERING INC.; and DOES 1-100, inclusive Motion Date: August 28, 2023 18 Time: 8:30 a.m. Defendants. Dept: $23 19 Judge: Hon. Donald Alvarez 20 AND RELATED CROSS-ACTION(S) Action Filed: June 11, 2020 Trial Date: October 9, 2023 21 22 23 PLEASE TAKE NOTICE that on August 28, 2023, at 8:30 a.m. or as soon thereafter as 24 the matter may be heard before the Honorable Donald Alvarez in Department 23 ofthe California 25 Superior Court for the County of San Bernardino located at 247 West Third Street, San 26 Bemardino, California 92415, Defendant KING EQUIPMENT LLC (DOE 1) (“King” herein) will 27 and hereby move this Court for an Order Granting Summary Judgment in favor 0f King and 28 against Plaintiffs RAFAEL CARVAJAL MARQUEZ (“Marquez” herein) and his wife 1 DEFENDANT KING EQUIPMENT LLC’S NOTICE OF MOTION AND M OTION FOR SUMNIARY JUDGMENT AS TO PLAINTIFFS' COMPLAINT ‘_ k x