On October 16, 2018 a
Motion,Ex Parte
was filed
involving a dispute between
Safe Products For Californians, Llc,
and
360 Labs, Inc,
Homegoods, Inc.,
T.J. Maxx Of Ca, Llc,
for Other Complaint (Not Spec) Unlimited (42)
in the District Court of Santa Clara County.
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Tanya E. Moore, SBN 206683 Electronically Filed
Moore LAW FIrM, P.C.
300 South First Street, Suite 342 by Superior Court of CA,
San Jose, California 95113 County of Santa Clara,
Telephone (408) 298-2000 on 7/22/2020 4:34 PM
Facsimile (408) 298-6046 Reviewed By: M Vu
E-mail: service@moorelawfirm.com
Case #18CV336490
Attorney for Plaintiff Envelope: 4644216
Safe Products for Californians, LLC
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SANTA CLARA
10
11 SAFE PRODUCTS FOR CALIFORNIANS, ) No. 18CV336490
LLC,
12 ) NOTICE OF MOTION AND MOTION
Plaintiff, ) TO APPROVE PROPOSITION 65
13 SETTLEMENT AND CONSENT
vs. ) JUDGMENT
14 )
HOMEGOODS, INC., et al.
15 ) Date: September 15, 2020
Defendants. ) Time: 9:00 a.m.
16 Department: 20
17 ) Honorable Socrates P. Manoukian
)
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NOTICE OF MOTION AND MOTION
TO APPROVE PROPOSITION 65 SETTLEMENT AND CONSENT JUDGMENT
Page 1
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that on September 15, 2020 at 9:00 a.m., or as soon
thereafter as counsel may be heard, in Department 20 of the Santa Clara County Superior Court
located at 191 North First Street, San Jose, California, Plaintiff, Safe Products for Californians,
LLC (“Plaintiff”), will and hereby does, move the Court for its approval of the settlement
reached in this action for alleged violations of California Health & Safety Code § 25249.6 et
seq. (Proposition 65), and requests that the Court approve the “[Proposed] Consent Judgment,”
setting forth the terms and conditions of the parties’ settlement. Plaintiff moves this Court,
pursuant to California Health & Safety Code § 25249.7(f)(4), for an order approving the
10 settlement and entry of the “[Proposed] Judgment Pursuant to Terms of Proposition 65
11 Settlement and Consent Judgment” submitted herewith.
12 The Motion is based upon this Notice, the supporting Memorandum of Points and
13 Authorities, Declaration of Tanya E. Moore with exhibits, and Affidavit of Compliance, all
14 filed herewith; the complete files and records in this action; and any other evidence and
15 argument that may be presented to the Court at the time of the hearing.
16
17 Dated: July 21, 2020 MOORE LAW FIRM, P.C.
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19 /s/ Tanya E. Moore
Tanya E. Moore
20 Attorney for Plaintiff,
21 Safe Products for Californians, LLC
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NOTICE OF MOTION AND MOTION
TO APPROVE PROPOSITION 65 SETTLEMENT AND CONSENT JUDGMENT
Page 2
Document Filed Date
July 22, 2020
Case Filing Date
October 16, 2018
Category
Other Complaint (Not Spec) Unlimited (42)
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Tanya E. Moore, SBN 206683 Electronically Filed Moore LAW FIrM, P.C. 300 South First Street, Suite 342 by Superior Court of CA, San Jose, California 95113 County of Santa Clara, Telephone (408) 298-2000 on 7/22/2020 4:34 PM Facsimile (408) 298-6046 Reviewed By: M Vu E-mail: service@moorelawfirm.com Case #18CV336490 Attorney for Plaintiff Envelope: 4644216 Safe Products for Californians, LLC SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA 10 11 SAFE PRODUCTS FOR CALIFORNIANS, ) No. 18CV336490 LLC, 12 ) NOTICE OF MOTION AND MOTION Plaintiff, ) TO APPROVE PROPOSITION 65 13 SETTLEMENT AND CONSENT vs. ) JUDGMENT 14 ) HOMEGOODS, INC., et al. 15 ) Date: September 15, 2020 Defendants. ) Time: 9:00 a.m. 16 Department: 20 17 ) Honorable Socrates P. Manoukian ) 18 19 20 21 22 23 24 25 26 27 28 NOTICE OF MOTION AND MOTION TO APPROVE PROPOSITION 65 SETTLEMENT AND CONSENT JUDGMENT Page 1 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that on September 15, 2020 at 9:00 a.m., or as soon thereafter as counsel may be heard, in Department 20 of the Santa Clara County Superior Court located at 191 North First Street, San Jose, California, Plaintiff, Safe Products for Californians, LLC (“Plaintiff”), will and hereby does, move the Court for its approval of the settlement reached in this action for alleged violations of California Health & Safety Code § 25249.6 et seq. (Proposition 65), and requests that the Court approve the “[Proposed] Consent Judgment,” setting forth the terms and conditions of the parties’ settlement. Plaintiff moves this Court, pursuant to California Health & Safety Code § 25249.7(f)(4), for an order approving the 10 settlement and entry of the “[Proposed] Judgment Pursuant to Terms of Proposition 65 11 Settlement and Consent Judgment” submitted herewith. 12 The Motion is based upon this Notice, the supporting Memorandum of Points and 13 Authorities, Declaration of Tanya E. Moore with exhibits, and Affidavit of Compliance, all 14 filed herewith; the complete files and records in this action; and any other evidence and 15 argument that may be presented to the Court at the time of the hearing. 16 17 Dated: July 21, 2020 MOORE LAW FIRM, P.C. 18 19 /s/ Tanya E. Moore Tanya E. Moore 20 Attorney for Plaintiff, 21 Safe Products for Californians, LLC 22 23 24 25 26 27 28 NOTICE OF MOTION AND MOTION TO APPROVE PROPOSITION 65 SETTLEMENT AND CONSENT JUDGMENT Page 2