On June 11, 2020 a
Motion-Secondary
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.
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GRQQBNAL
David J. Byassee, Bar No. 244509
James Whitemyer, Bar No. 185528
PLAIN LEGAL PC
2005 Via Vina
San Clemente, California 92673
(714) 587-5214
BymK
M&WN
service@plain—legal.com
Attorneys for Defendant/Cross-Defendant
KING EQUIPMENT, LLC (DOE 1) NICOLE
O'DM’ER,
\OOOQQ
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
10
11 RAFAEL CARVAJAL MARQUEZ; Case No. CIVD52010310
ADRIANA QUINTERO MADRIGAL,
12 MEMORANDUM OF POINTS AND
Plaintiffs, AUTHORITIES IN SUPPORT OF
13 DEFENDANT KING EQUIPMENT LLC’S
v. MOTION FOR SUMMARY JUDGMENT
PLAN 14 AS TO PLAINTIFFS’ COMPLAINT
LEGAL
GENIE INDUSTRIES, INC.; TEREX
[Filed concurrently with Notice of Motion; Separate
15 CORPORATION; DUKE REALTY
Statement of Undisputed Material Facts; Declaration
LIMITED PARTNERSHIP; DUKE
Ernest William Quijada; Declaration of Attorney
16 REALTY CORPORATION; GREGG
GENERAL James Whitemyer; Index and Compendium of
ELECTRIC, 1NC.; I.E.
and DOES 1-100, Exhibits; and Proposed Order]
17 ENGINEERING INC.;
inclusive
18 Motion Date: August 28, 2023
Defendants. Time: 8:30 a.m.
19 Dept: $23
Judge: Hon. Donald Alvarez
20 AND RELATED CROSS—ACTION(S) Action Filed: June 11, 2020
Trial Date: October 9, 2023
21
22
23
24
25
26
27
28
1
MEMORANDUM OF POINTS AND AUTHORITIES
VED
RECEIOF CAUFORNIA
COURT
SUPERIOR OF SAN BERNARDINO
COUNTY
JUN 12 2023
Rina Phillips
Document Filed Date
June 12, 2023
Case Filing Date
June 11, 2020
Category
Personal Injury Non-Motor Vehicle Unlimited
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GRQQBNAL David J. Byassee, Bar No. 244509 James Whitemyer, Bar No. 185528 PLAIN LEGAL PC 2005 Via Vina San Clemente, California 92673 (714) 587-5214 BymK M&WN service@plain—legal.com Attorneys for Defendant/Cross-Defendant KING EQUIPMENT, LLC (DOE 1) NICOLE O'DM’ER, \OOOQQ SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO 10 11 RAFAEL CARVAJAL MARQUEZ; Case No. CIVD52010310 ADRIANA QUINTERO MADRIGAL, 12 MEMORANDUM OF POINTS AND Plaintiffs, AUTHORITIES IN SUPPORT OF 13 DEFENDANT KING EQUIPMENT LLC’S v. MOTION FOR SUMMARY JUDGMENT PLAN 14 AS TO PLAINTIFFS’ COMPLAINT LEGAL GENIE INDUSTRIES, INC.; TEREX [Filed concurrently with Notice of Motion; Separate 15 CORPORATION; DUKE REALTY Statement of Undisputed Material Facts; Declaration LIMITED PARTNERSHIP; DUKE Ernest William Quijada; Declaration of Attorney 16 REALTY CORPORATION; GREGG GENERAL James Whitemyer; Index and Compendium of ELECTRIC, 1NC.; I.E. and DOES 1-100, Exhibits; and Proposed Order] 17 ENGINEERING INC.; inclusive 18 Motion Date: August 28, 2023 Defendants. Time: 8:30 a.m. 19 Dept: $23 Judge: Hon. Donald Alvarez 20 AND RELATED CROSS—ACTION(S) Action Filed: June 11, 2020 Trial Date: October 9, 2023 21 22 23 24 25 26 27 28 1 MEMORANDUM OF POINTS AND AUTHORITIES VED RECEIOF CAUFORNIA COURT SUPERIOR OF SAN BERNARDINO COUNTY JUN 12 2023 Rina Phillips