On April 19, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
State Farm General Insurance Company,
and
Air Vent Inc.,
Does 1-20,
for Other non-PI/PD/WD Tort Unlimited
in the District Court of San Bernardino County.
Preview
\a \a
QWGRNAL
Keith E. Smith (State Bar No. 244505)
kesmith@wshblaw.com
SUPERIOR C UlfiT%FQAUFORNIA
0|
Courtney Jakofsky (State Bar N0. 31 1368) COUNTY OF SAN BERNAHDINO
cjakofsky@wshblaw.com SAN BERNARDINO DISTRICT
Munther Tabel (State Bar N0. 351 145)
mutabel@wshblaw.com MAR 19 202“
W000, SMITH, HENNING & BERMAN LLP
21 804 Cactus Avenue, Suite 200 @jrvfl
L3 ‘-
Riverside. California 92518-3010
G ar cia Depuw
,
BY, stephanne .
Phone: 95] 779 5000 O Fax: 951 755 1650
Attorneys for Defendant/Cross-Complainant, AIR VENT, INC.
SUPERIOR COURT 0F THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT
gz owd - 075434 $927
LLP
11 STATE FARM GENERAL INSURANCE Case N0. CIVSBZ] l 1551
1650
COMPANY,
200 12 DEFENDANT/CROSS-COMPLAINANT
INC.'S NOTICE OF MOTION
755
BERMAN
9251&3010
Plaintiff, AIR VENT,
&
SUITE
951
13 AND MOTION TO FILE
Law
rAx
.
v. CONFIDENTIAL DECLARATIONS OF
HENNING
al AVENUE,
CALIFORNIA
l4 COURTNEY JAKOFSKY AND BRAD
Aflomeys
7795000
AIR VENT. INC. and DOES 1-20, HOLLAND UNDER SEAL IN
CACTUS
951
15 INCLUSIVE, OPPOSITION TO POWERMAX
SMITH, ELECTRIC CO., LIMITED,
GUANGDONG'S MOTION TO QUASH
RIVERSIDE.
21804 l6 Defendant.
TELEPHONE
WOOD‘
l7 [Filed concurrently with [Proposed] Order]
l8 Date: June l2, 2024
Time: 8:30 a.m.
19 Dept; S33
20 [Assigned for All Purposes to Hon. Stephanie
Tanada. Dept. S33]
21
AND ALL RELATED CRoss-ACTIONS. Action Filed: April l9, 2021
22 Trial Date: None Set
23
24 TO ALL PARTIES AND THEIR COUNSEL OF RECORD:
25 PLEASE TAKE NOTICE that on June 12. 2024 at 8:30 a.m., 0r as soon thereafter as the
matter may be heard, in Dept. S33 0f the Superior Court of California, County of San Bemardino,
26
27 located at 247 W. 3rd Street. San Bemardino, CA 924] 5, Defendant/Cross-Complainant. AIR
28 VENT. INC. ("AVI"), by and through its attorneys of record. will and hereby does move this
317557131 119670005 Case No. CIVSBZI 155] 1
AIR VENT. INC.'S NOTICE OF MOTION TO FILE CONFIDENTIAL DECLARATIONS UNDER SEAL IN
OPPOSITION TO POWERMAX ELECTRIC CO., LIMITED, GUANGDONG'S MOTION TO QUASH
Court for an order t0 file the Confidential Declarations of Courtney Jakofsky and Brad Holland
under Court seal in opposition to Cross-Defendant's, POWERMAX ELECTRIC CO., LIMITED,
GUANGDONG ("POWERMAX"). Motion to Quash based upon Lack of Personal Jurisdiction.
AVI is entitled t0 this reliefpursuant to California Rules ofCourt, Rule 2.550 and 2.551 on
the following grounds:
l. AVI has an overriding interest in maintaining the confidentiality of the third party
records that overcomes the right of public access to the record;
OOWV¢ 2. This overriding interest supports sealing the records;
3. A substantial probability exists that the overriding interest will be prejudiced if the
Confidential Declarations are not sealed;
LLP
ll 4. No less restrictive means exist to achieve AVl's overriding interest in sealing the
1650
200
8-3010
Confidential Declarations; and
755
BERMAN
SUITE 951
8-
9251
l3 5. The proposed sealing is narrowly tailored.
FAX
Law
at
o
HENNING
AVENUE,
CALIFORNIA
l4 This Motion is based on this notice. the attached memorandum of points and authorities,
7795000
Attorneys
CACTUS
15 the Declaration of Courtney Jakofsky, all pleadings, documents and records on file in this action.
951
SMITH.
RIVERSIDE,
21804
16 and upon such other oral argument and documentary evidence as may be presented at the time of
YELEPHONE
WOOD,
l7 hearing.
l8 DATED: March 19, 2024 WOOD. SMITH. HENNING & BERMAN LLP
l9
20
By:
i
Ax/‘fi
21
l
é;
K 1TH E. SMITH
COURTNEY JAKOFSKY
22 MUNTHER TABEL
Attorneys for Defendant/Cross-Complainant. AIR
23
VENT. INC.
24
25
26
27
28
317557131 119670005 -2- Case No. CIVSle 1 155]
AIR VENT, INC.‘S NOTICE OF MOTION TO FILE CONFIDENTIAL DECLARATIONS UNDER SEAL IN
OPPOSITION TO POWERMAX ELECTRIC CO.. LIMITED, GUANGDONG'S MOTION TO QUASH
Document Filed Date
March 19, 2024
Case Filing Date
April 19, 2021
Category
Other non-PI/PD/WD Tort Unlimited
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\a \a QWGRNAL Keith E. Smith (State Bar No. 244505) kesmith@wshblaw.com SUPERIOR C UlfiT%FQAUFORNIA 0| Courtney Jakofsky (State Bar N0. 31 1368) COUNTY OF SAN BERNAHDINO cjakofsky@wshblaw.com SAN BERNARDINO DISTRICT Munther Tabel (State Bar N0. 351 145) mutabel@wshblaw.com MAR 19 202“ W000, SMITH, HENNING & BERMAN LLP 21 804 Cactus Avenue, Suite 200 @jrvfl L3 ‘- Riverside. California 92518-3010 G ar cia Depuw , BY, stephanne . Phone: 95] 779 5000 O Fax: 951 755 1650 Attorneys for Defendant/Cross-Complainant, AIR VENT, INC. SUPERIOR COURT 0F THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT gz owd - 075434 $927 LLP 11 STATE FARM GENERAL INSURANCE Case N0. CIVSBZ] l 1551 1650 COMPANY, 200 12 DEFENDANT/CROSS-COMPLAINANT INC.'S NOTICE OF MOTION 755 BERMAN 9251&3010 Plaintiff, AIR VENT, & SUITE 951 13 AND MOTION TO FILE Law rAx . v. CONFIDENTIAL DECLARATIONS OF HENNING al AVENUE, CALIFORNIA l4 COURTNEY JAKOFSKY AND BRAD Aflomeys 7795000 AIR VENT. INC. and DOES 1-20, HOLLAND UNDER SEAL IN CACTUS 951 15 INCLUSIVE, OPPOSITION TO POWERMAX SMITH, ELECTRIC CO., LIMITED, GUANGDONG'S MOTION TO QUASH RIVERSIDE. 21804 l6 Defendant. TELEPHONE WOOD‘ l7 [Filed concurrently with [Proposed] Order] l8 Date: June l2, 2024 Time: 8:30 a.m. 19 Dept; S33 20 [Assigned for All Purposes to Hon. Stephanie Tanada. Dept. S33] 21 AND ALL RELATED CRoss-ACTIONS. Action Filed: April l9, 2021 22 Trial Date: None Set 23 24 TO ALL PARTIES AND THEIR COUNSEL OF RECORD: 25 PLEASE TAKE NOTICE that on June 12. 2024 at 8:30 a.m., 0r as soon thereafter as the matter may be heard, in Dept. S33 0f the Superior Court of California, County of San Bemardino, 26 27 located at 247 W. 3rd Street. San Bemardino, CA 924] 5, Defendant/Cross-Complainant. AIR 28 VENT. INC. ("AVI"), by and through its attorneys of record. will and hereby does move this 317557131 119670005 Case No. CIVSBZI 155] 1 AIR VENT. INC.'S NOTICE OF MOTION TO FILE CONFIDENTIAL DECLARATIONS UNDER SEAL IN OPPOSITION TO POWERMAX ELECTRIC CO., LIMITED, GUANGDONG'S MOTION TO QUASH Court for an order t0 file the Confidential Declarations of Courtney Jakofsky and Brad Holland under Court seal in opposition to Cross-Defendant's, POWERMAX ELECTRIC CO., LIMITED, GUANGDONG ("POWERMAX"). Motion to Quash based upon Lack of Personal Jurisdiction. AVI is entitled t0 this reliefpursuant to California Rules ofCourt, Rule 2.550 and 2.551 on the following grounds: l. AVI has an overriding interest in maintaining the confidentiality of the third party records that overcomes the right of public access to the record; OOWV¢ 2. This overriding interest supports sealing the records; 3. A substantial probability exists that the overriding interest will be prejudiced if the Confidential Declarations are not sealed; LLP ll 4. No less restrictive means exist to achieve AVl's overriding interest in sealing the 1650 200 8-3010 Confidential Declarations; and 755 BERMAN SUITE 951 8- 9251 l3 5. The proposed sealing is narrowly tailored. FAX Law at o HENNING AVENUE, CALIFORNIA l4 This Motion is based on this notice. the attached memorandum of points and authorities, 7795000 Attorneys CACTUS 15 the Declaration of Courtney Jakofsky, all pleadings, documents and records on file in this action. 951 SMITH. RIVERSIDE, 21804 16 and upon such other oral argument and documentary evidence as may be presented at the time of YELEPHONE WOOD, l7 hearing. l8 DATED: March 19, 2024 WOOD. SMITH. HENNING & BERMAN LLP l9 20 By: i Ax/‘fi 21 l é; K 1TH E. SMITH COURTNEY JAKOFSKY 22 MUNTHER TABEL Attorneys for Defendant/Cross-Complainant. AIR 23 VENT. INC. 24 25 26 27 28 317557131 119670005 -2- Case No. CIVSle 1 155] AIR VENT, INC.‘S NOTICE OF MOTION TO FILE CONFIDENTIAL DECLARATIONS UNDER SEAL IN OPPOSITION TO POWERMAX ELECTRIC CO.. LIMITED, GUANGDONG'S MOTION TO QUASH