Motion-Secondary: Seneca Insurance Company, Inc. A/S/O Southern States Pavement Markings, Inc. v. Kumho Tire U.S.A., Inc.

On August 21, 2018 a Motion-Secondary was filed involving a dispute between Seneca Insurance Company, Inc. A S O Southern States Pavement Markings, Inc., and Kumho Tire U.S.A., Inc., for Torts - Product Liability (defective product) in the District Court of New York County.

Preview
FILED: NEW YORK COUNTY CLERK 06/18/2019 07:20 AM INDEX NO. 157749/2018
NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 06/18/2019

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
---------------------------------------- --------------------------------------X

SENECA INSURANCE COMPANY, INC. a/s/o

Southern States Pavement Markings, Inc., Index No

Plaintiff,
- against
-

KUMHO TIRE U.S.A., INC., Motion

July 18,

Defendant.

............-----------¬----------------------------------------------------------X

MEMORANDUM OF LAW IN SUPPORT OF KUMHO TIR
INC.'S MOTION TO DISMISS

LITTLETON PARK JOYCE UGHETTA & KELLY LLP
1 of 19 Attorneys for Defendant
FILED: NEW YORK COUNTY CLERK 06/18/2019 07:20 AM INDEX NO. 157749/2018
NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 06/18/2019

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
-------------------------------------------------------------------------------x
SENECA INSURANCE COMPANY, INC. a/s/o
Southern States Pavement Markings, Inc., Index No. 157749/2018

Plaintiff, MEMORANDUM OF
- against - LAW IN SUPPORT OF
KUMHO TIRE U.S.A.,
KUMHO TIRE U.S.A., INC., INC.'S MOTION TO
DISMISS
Defendant.
---------------------------------------- -------------------------x

INTRODUCTION

Defendant Kumho Tire U.S.A., Inc. ("KTUSA ") respectfully submits this memorandum

of law in support of its motion for an order pursuant to CPLR §327 dismissing the complaint

brought by plaintiff Seneca Insurance Company, Inc. ("Seneca") a/s/o Southern States Pavement

Markings, Inc. ("Southern States") and granting KTUSA such order and further relief as the

Court deems just and proper.

FACTUAL BACKGROUND

Seneca commenced the instant subrogation action seeking to recover over $400,000 itpaid

Southern States. Seneca alleges that Southern States owned a truck that was involved in a

December 10, 2016 accident in Deland, Florida because of an alleged failure of a Kumho brand

tire. Southern States is a Florida corporation with a principal place of business in Florida, and

KTUSA is a Georgia corporation with a principal place of business in Georgia. While KTUSA

has not had an opportunity to inspect the tire that is allegedly involved in the incident giving rise

to this lawsuit to verify its identity, and plaintiff is alleging that the tire is a Kumho tire simply

based on three (3) tread pieces that allegedly came off from the tire,if the tire that was allegedly

2 of 19
FILED: NEW YORK COUNTY CLERK 06/18/2019 07:20 AM INDEX NO. 157749/2018
NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 06/18/2019

involved in the incident was indeed a Kumho tire,KTUSA would have sold it from one of its

distribution centers in California or Georgia. The only contact with New York in this suit is that

States'
Seneca, Southern insurer, is a New York corporation with a principal place of business in

New York.

Seneca claimed the following in its discovery responses:

a. Southern States allegedly purchased the tire from Jax Commercial Tire Inc. ("Jax")

which is located at 1526 Industrial Blvd., Jacksonville, Florida. Jax allegedly

States'
installed the subject Kumho tire on Southern subject truck. (Exhibit "G",

$2). Jax is a Florida Corporation with a principal place of business in Florida.

(Exhibit "H", Jax's corporate history for Florida's secretary of state website).

Seneca produced Jax's sales documents concerning tires Southern States

purchased. None of the documents show that Jax sold Southern States a Kumho

tire. (Exhibit *, Jax's sales documents)

b. Seneca admitted that the subject truck was last in possession of Southern States

located at 10090 US-1, St. Augustine, Florida. Seneca asserted that Southern States

is no longer in possession of the subject truck. (Exhibit "G", $3).

c. Seneca claimed that its employee Roosevelt Byrd was driving the subject truck at

the time of the incident, and that Byrd lives in St. Augustine, Florida. (Exhibit "G",

¶6 and 27).

d. Seneca asserted that Jeff Burr, a Southern States employee, picked up the tire pieces

3 of 19
FILED: NEW YORK COUNTY CLERK 06/18/2019 07:20 AM INDEX NO. 157749/2018
NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 06/18/2019

that allegedly came from the subject truck. (Exhibit "G", $26).

e. Seneca admitted that the subject truck and tirepieces were towed to Horton Truck

Service ("Horton"), located at 2525 West Beaver Street, Jacksonville, Florida, and

States'
that Horton towed the vehicle and tire pieces back to Southern facility.

(Exhibit "G", ¶26).

f. Seneca asserted that itwill call the following witnesses at trial:

i. Erik DeMartinis, Johns Eastern Claims, Maitland, Florida (Seneca's claim

adjuster)

ii. Melvin Carter and Marci Zemon-Stowell, Southern States, St. Augustine,

Florida.

iii. Roosevelt Byrd, St. Augustine, Florida. (truck operator at the time of the

incident)

iv. Emanuel Wood, Hastings, Florida

v. Florida Highway Patrol Police officers and/or fire department personnel

that responded to the incident.

vi. KTUSA representatives that have knowledge of Seneca's claims.

vii. Greg McGovern, Seneca, New York, New York. (Exhibit "G", $27).

Except for Greg McGovern, all the witnesses are from Florida or Georgia.

In response to KTUSA's request for production of documents, Seneca produced a record

that Southern Wrecker & Recovery of St. Augustine, Florida towed the subject truck from the

location of the accident to Southern States on December 11, 2016.

4 of 19
FILED: NEW YORK COUNTY CLERK 06/18/2019 07:20 AM INDEX NO. 157749/2018
NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 06/18/2019

SUMMARY OF ARGUMENT

This Court should dismiss the Verified Complaint on the doctrine of forum non conveniens

because (1) Florida is an adequate alternative forum to address Seneca's claims; (2) Southern

States, Seneca's insured, is a Florida corporation with a principal place of business in Florida; (3)

KTUSA is a Georgia corporation with a principal place of business in Georgia; (4) KTUSA did

not distribute the subject tire from New York; (4) the entity that sold Southern States the tire is a

Florida Corporation with a principal place of business in Florida; (5) the incident at issue occurred

in Florida; (6) key witnesses are not New York residents and are otherwise not subject to

compulsory process in this Court; (7) the only connection this suit has with New York is Seneca,

States'
Southern insurance carrier; (8) there is no justification for burdening the New York courts

with this matter; and (9) Seneca can reinstate suit in Florida without undue hardship.

stalM82K

I. THE DOCTRINE OF FORUM NON CONVZNIENS COMPELS DISMISSAL
OF THIS ACTION.

A. Legal Standard.

An action, properly subject to jurisdiction in the courts of this State, may be dismissed

under the doctrine of forum non conveniens where itis determined that the action would be better

adjudicated in another forum. CPLR 327(a); see e.g. Mashreqbank PSC v. Ahmed Hamad Al

Gosaibi d'c Bros. Co., 23 N.Y.3d 129 at 135-136, 989 N.Y.S.2d 458 at 460-461 (2014). The factors

in weighing such a motion to dismiss include (1) the location of the events giving rise to the action,

(2) potential hardship to the defendant, (3) the burden on New York courts, (4) the availability of

an alternate forum, (5) the location of potential witnesses and documents, (6) the applicability of

foreign law, and (7) the residence of the parties, with no one factor controlling. See Islamic

5 of 19
FILED: NEW YORK COUNTY CLERK 06/18/2019 07:20 AM INDEX NO. 157749/2018
NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 06/18/2019

Republic of Iran v. Pahlavi, 62 N.Y.2d 474 at 479, 478 N.Y.S.2d 597 at 600 (1984), cert denied

469 U.S. 1108, 105 S. Ct. 783 (1985); Ghose v. CNA Reins. Co. Ltd., 43 A.D.3d 656 at 660, 841

(1"
N.Y.S.2d 519 Dept. 2007), lv denied 10 N.Y.3d 712, 861 N.Y.S2d 273 (2008); Shin-Etsu

(1"
Chem. Co. v. ICICI Bank Ltd., 9 A.D.3d 171 at 175-176, 777 N.Y.S.2d 69 at 73 Dept. 2004).

Where there is no substantial nexus to this state, dismissal based upon forum non conveniens is

(1"
warranted. Blueye Navigation v. Den Norske Bank, 239 AD2d 192, 658 N.Y.S.2d 9 Dept.

1997).

B. New York Plays No Role in This Dispute: The Real Parties in Interest are
Nonresidents and the Incident Occurred in Florida.

Forum non conveniens dictates that this case should be dismissed because New York plays

no role in this dispute between non-resident defendant KTUSA and Seneca which is a subrogee to

Southern States, a non-resident entity. "[O]ur courts should not be under any compulsion to add

to their heavy burdens by accepting jurisdiction of a cause of action having no substantial nexus

with New York". Shin-Etsu Chem. Co. v. ICICIBank Ltd., 9 A.D.3d 171 at 176, 777 N.Y.S.2d 69

(1"
at 73 Dept. 2004), citing Silver v. Great Am. Ins. Co., 29 N.Y.2d 356 at 361, 328 N.Y.S.2d 398

(1972). It iswell established that a substantial nexus does not lie where the events giving rise to

the action occurred entirely in a foreign jurisdiction. see Viking Global Equities, LP v. Porsche

36(1"
Automobil Holding SE, 101 A.D.3d 640 at 641, 958 N.Y.S.2d 35 at Dept. 2012).

(1"
For example, in Avery v. Pfizer, Inc., 68 A.D.3d 633, 891 N.Y.S.2d 369 Dept. 2009),

plaintiff commenced a product liability action based upon the use of defendant's drug. The First

Department affirmed the dismissal of plaintiff s complaint on forum non conveniens grounds

where, amongst other things, plaintiff filled prescriptions for, ingested, and suffered injuries as a

6 of 19
FILED: NEW YORK COUNTY CLERK 06/18/2019 07:20 AM INDEX NO. 157749/2018
NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 06/18/2019

result of the drug in the State of Georgia, rather than New York.

In Matter of Alla v. American Univ. of Antigua, Coll. of Medicine, 106 A.D.3d 570, 965

(ISt
N.Y.S.2d 469 Dept. 2013), the First Department affirmed the dismissal of a petition on grounds

of forum non conveniens where the location of the events giving rise to the action centered almost

entirely in Antigua, rather than in New York. In Rakuten Bank, Ltd. v. Royal Bank of Can., 136

(1st
A.D. 3d 481, 24 N.Y.S. 3d 638 Dept. 2016), the First Department, once again, affirmed the

dismissal of an action based on forum non conveniens in the absence of a substantial nexus with

New York; all aspects of the sale at issue occurred out-of-state.

Here, Seneca pleads no facts and produces no evidence alleging a connection to New

York, other than itis a New York corporation. Nearly allof the alleged conduct at issue occurred

in Florida.

C. The Unnecessary Burden on New York Courts Weighs in Favor of
Dismissal.

New York courts should not add to their already substantial burden by presiding over cases

that have littleor no nexus with New York. Pahlavi, 62 N.Y.2d at 478, 478 N.Y.S.2d at 599

("courts are not required to add to their financial and administrative burdens by entertaining

litigation which does not have any connection with this State"). Because nearly all the alleged

conduct occurred in Florida, New York courts "are not required to add to their financial and

administrative burdens by entertaining litigation which does not have any connection with

State."
this In re OxyContin H, 76 A.D.3d 1019, 1020, 909 N.Y.S.2d 239, 241 (2d Dep't 2010)

"improvidently"
(quoting Pahlavi, 62 N.Y.2d at 478) (where court denied the motion to dismiss).

"The applicability of foreign law is an important consideration in determining a forum non

7 of 19
FILED: NEW YORK COUNTY CLERK 06/18/2019 07:20 AM INDEX NO. 157749/2018
NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 06/18/2019

conveniens motion and weighs in favor of dismissal". Flame S.A. v. Worldlink In

(1St
107 A.D.3d 436 at 438, 967 N.Y.S.2d 328 at 331 Dept. 2013), lv denied 2

N.Y.S.2d 561 (2013) (internal quotations omitted). "Under New York's

approach, courts seek to effect the law of the jurisdiction having the greatest in

the particular issue". Mashreqbank PSC v. Ahmed Hamad Al Gosaibi & Bros. C

at 138, 989 N.Y.S.2d 458 at 462 (2014) (internal citations and quotations omitted).

jurisdiction where the tort occurred generally will apply because that jurisdiction

interest in
regulating
behavior within its borders. Devore v. Pfzer Inc., 58 A.D.

[1St
N.Y.S.2d 425, 428 Dept. 2008], lv denied 12 N.Y.3d 703, 876 N.Y.S.2d 704

matter involves an allegedly defective product, the situs of the tort is the place

than the location where the
allegedly
defective product was manufactured. See

Scouts of Am., 65 N.Y.2d 189, 491 N.Y.S.2d 90 (1985); Devore v. Pfzer Inc., 5

(1st
N.Y.S.2d 425 Dept. 2008), lv denied 12 N.Y.3d 703, 876 N.Y.S.2d 704 (2009

Here, the situs of the alleged tort was Florida, not New York. Indeed,

admission, this subrogation action arose out of a Florida accident allegedly in

tire. The application of Florida law to the instant dispute mandates di

Mashreqbank PSC v. Ahmed Hamad Al Gosaibi & Bros. Co., 23 N.Y.3d 129,

(2014) (holding that New York8 ofwas19 an inconvenient forum for a dispute between
FILED: NEW YORK COUNTY CLERK 06/18/2019 07:20 AM INDEX NO. 157749/2018
NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 06/18/2019

D. No Liability Witnesses are Located in New York.

Where the resolution of a claim requires documentary proof and witness testimony, the

location of the witnesses and any relevant documents becomes an important factor in determining

a dismissal motion based upon forum non conveniens. See Shin-Etsu Chem. Co. v. ICICI Bank

(1st
Ltd., 9 A.D.3d 171 at 177-178, 777 N.Y.S.2d 69 at 74 Dept. 2004), citing World Point Trading

(1st
PTE. V Credito Italiano, 225 A.D.2d 153 at 161, 649 N.Y.S.2d 689 at 693-694 Dept. 1996).

To carry its burden on this factor, a defendant must delineate how witnesses not subject to

compulsory process are critical to the action. Piper Aircraft Co. v. Reyno, 454 U.S. 235 at 258,

102 S. Ct. 252 at 267 (1981). Defendant is not, however, required to identify each potentially

critical witness, nor to submit affidavits that provide significant evidentiary detail. Piper, 454 U.S.

at 258, 102 S. Ct. at 267 (1981) (rejecting the suggestion that defendants seeking forum dismissal

must submit affidavits identifying the witnesses they would call and the testimony such witnesses

would provide because itwould defeat the purpose of the motion); Fitzgerald v. Texaco, Inc., 521

(2nd
F.2d 448 Cir. 1975) (holding that the trialcourt did not abuse itsdiscretion in failing to require

detailed disclosure by the defendants of the names of their proposed witnesses and the substance

of their testimony).

To illustrate, in Shin-Etsu Chem. Co. v. ICICI Bank Ltd., 9 A.D.3d 171, 777 N.Y.S.2d 69

(1st
Dept. 2004), the First Department reversed an order denying defendant's motion to dismiss for

forum non conveniens where the written record of the transaction at issue, documents and

correspondence were located in India, and witnesses with personal knowledge were located

overseas. Likewise, in Finance & Trading Ltd. v. Rhodia S.A., 28 A.D.3d 346, 816 N.Y.S.2d 7

(1st
Dept. 2006), app denied 7 N.Y.3d 706, 837 N.Y.S.2d 1 (2006), the First Department affirmed

an order dismissing plaintiff's complaint on forum non conveniens grounds where the majority of

9 of 19
FILED: NEW YORK COUNTY CLERK 06/18/2019 07:20 AM INDEX NO. 157749/2018
NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 06/18/2019

the relevant documents and witnesses were located in France.

Here, the testimony of Florida non-party witnesses, including the investigating

department personnel, Jax's personnel that allegedly sold the subject tire, and

employees with knowledge concerning the purchase and use of the tire, and th

are material and necessary to this case. KTUSA therefore may not be able to com

of necessary Florida non-party witnesses and the production of Florida documents.

v. Harmony Gold Mining Co., 2011 U.S. Dist. LEXIS 138543 (S.D.N.Y. 2011)

where all potential fact witnesses were located in South Africa, South African

to respond to letters rogatory issued under the Hague Convention for over one

The concentration of evidence in Florida weighs heavily in favor

location of the witnesses is an important consideration when analyzing wheth

case under the doctrine of forum non conveniens. See, e.g., Silver Lane A

Bellatore LLC, 24 Misc.3d 1218(A), 8 9 7 N. Y . S. 2 d 6 7 2 (Sup. Ct., N.

(that California would be more convenient for the majority of witnesses, "strong

favor of dismissal."); Shin-Etsu, 9 A.D.3d at 176 (dismissing on grounds

conveniens in part because it was "unlikely that the issue can be resolved withou

witnesses"
of calling
who were
10 of located
19 outside of New York).
FILED: NEW YORK COUNTY CLERK 06/18/2019 07:20 AM INDEX NO. 157749/2018
NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 06/18/2019

hardship to KTUSA. Garmendia v. O'Neill, 46 A.D.3d 361, 847 N.Y.S.2d 563 (1st Dept. 2007).

F. F. Plaintiffs can Reinstate Suit Without Undue Hardship or Prejudice in the

Available, Alternate Forum of Florida.

Although not a requirement for dismissal on the ground of forum non conveniens, New

York courts take care to ensure that an alternate forum is available to all parties where

practicable. Here, the parties have an available forum in the courts of Florida. See Boyle v

(2nd
Starwood Hotels & Resorts Worldwide, Inc., 110 A.D.3d 938, 939, 973 N.Y.S. 2d 728

2013) affirmed by 23 N.Y.3d 1012, 992 N.Y.S.2d 773 (2014). Litigation in Florida is neither

less practical nor more expensive than litigation in New York.

To further ensure Seneca can reinstate their suit in Florida, KTUSA will stipulate to

extend the limitations period, if necessary. However, the limitations period under Florida law

has yet to expire. Here, the incident occurred on or about December 10, 2016. The statutes of

limitations in Florida for a negligence, strict liability and breach of warranty actions are four (4)

years from the date of the accident. See Fla. Stat Section 95.11(3). If this Court dismisses the

Complaint based onforum non conveniens, the statutes of limitations will not have run anyway,

so Seneca cannot be prejudiced by promptly filing their action in Florida.

Clearly, Florida provides an adequate and more suitable forum in which to bring the

instant suit. As such, the Complaint should be dismissed in favor of a more convenient forum

in Florida.

CONCLUSION

WHEREFORE, Defendant Kumho Tire U.S.A., Inc. respectfully requests that this Court

enter an Order (i) dismissing the Complaint against the Defendant pursuant to CPLR §§ 327; and

11 of 19
FILED: NEW YORK COUNTY CLERK 06/18/2019 07:20 AM INDEX NO. 157749/2018
NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 06/18/2019

(ii) granting Defendant such other and further relief as this Court deems just, proper, and

equitable under the circumstances.

Dated: Purchase, New York
June 17, 2019

Respectfully submitted,

LITTLETON PARK JOYCE UGHETTA LY LLP

By:
ruce Ainbinder
Attor ys for Defendant
KUMHO TIRE U.S.A. INC.
The Centre at Purchase
Four Manhattanville Road, Suite 202

Purchase, New York 10577
Tel. (914) 417-3400
Our File No.: 00966.00536

To: Eric Goldberg, Esq.

Attorney for Plaintiff
146
555 Fifth Avenue, Floor

New York, New York 10017
Telephone: (212) 687-5066

12 of 19
FILED: NEW YORK COUNTY CLERK 06/18/2019 07:20 AM INDEX NO. 157749/2018
NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 06/18/2019

Positive
As of: June 17,20194:43 PM Z

~Ha es v. Harmonv Gold Ninino Co .

United States District Court for the Southern District of New York

November 29, 2011, Decided; December 2, 2011, Filed

08 Civ. 03653 (BSJ) (MHD)

Reporter

2011 U.S. Dist. LEXIS 138543; 2011 WL 6019219

JAMES J. HAYES, Individually and on Behalf of All
Evidence > Inferences 8
Others Similarly Situated, Plaintiff, v. HARMONY GOLD
MINING COMPANY LIMITED, Defendant.

Civil Procedure > Settlements
Subsequent History: Affirmed by Ha es v. Harmon

Go/d Minin Co. 2013 U.S. A . LEXIS 1941 2d Cir.

~HN1 k] Presumptions

Core Terms Courts may presume tatit-t-teso
arm
settlement is the result of

settlement, ProPosed settlement, damages, estimated, between capable c
experienced,

courts, attorney's fees, negotiations, per-share, scienter, discovery.

conflicting interest, settlement negotiations, securities

fraud, class action, requires, drop, calculation,

speculation, securities, Approving, citations, asserts,
arm' Civil Procedure > Special Pro
risks, cross-examination, s-length, hypothetical,
Actions > Compromise & Settl
experienced, probability, benefits, motions, rejects

Civil Procedure > Settlements

Agreements > General Overvie

Civil Procedure > Settlements

Agreements > of Agre
Validity

Proponents of a class action settlement under Fed. R.
HN g] Con
on tea Mt taaae
~Civ P 23 e dtd .not .have the burden to make an

affirmative showing of fairness bY a PrePonderance of
Under a settlement fairness
the evidence; the court could Presume fairness because
Second Circuit are instructed
arm'
the Parties emPloYed an s-length negotiation
13 of 19 detailed and thorough inveotigation
which included the use of an exPerienced
FILED: NEW YORK COUNTY CLERK 06/18/2019 07:20 AM INDEX NO. 157749/2018
NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 06/18/2019

2011 U.S. Dist. LEXIS 138543, *138543

yielding a particularized sum. The evaluation turns PRO HAC VICE, Saxena White,

instead on whether there is a range of reasonableness
For Harmony Gold Mining Compan
with respect to a settlement-
David Franklin Wertheimer, Steven

ATTORNEYS, Hogan Lovells US

NY; Mark D. Gately, Hogan & Har

Civil Procedure > Settlements > Settlement Baltimore, MD; Scott Haiber, PRO
Agreements > of Agreements Lovells US LLP (DC), Washington,
Validity

m±] Validity of Agresmants Judges: BARBARA S. JONES,
DISTRICT JUDGE.
A settlement amount's ratio to the maximum potential

recovery need not be the sole, or even the dominant, Opinion by: BARBARA S. JONES
consideration when assessing the settlement's fairness.

Opinion

Securities Law > ...> Elements of

Proof > Scienter > Irregularities
Accounting
Memorandum and Opinion

M ] Accounting Irregularities
BARBARA S. JONES

Proving scienter in a securities fraud case requires
UNITED STATES DISTRICT JUD
considerably more than quoting a passage from an

annual report that acknowledges problems with the On November the
10, 2011,

accounting system. final approval of the p
regarding
attorneys'
requested fees in this

reasons stated on the record,

> > million was approvedasfair,reasonable,and
Securities Law ... Securities Exchange Act of
attorneys'
> and the Court awarded
1934 Actions Implied Private Rights of

> one third of the total recovery.
Action Burdens of Proof
hearing, James J. Hayes

> > objections to the proposed settl
Securities Law ... Elements of

> fees in the form of a formal object
Proof Scienter >GeneralOverview

Case Info

Judge

PERRY, W Track Judge’s New Case

Case No.

(Subscribe to View)

Document Filed Date

June 18, 2019

Case Filing Date

August 21, 2018

County

Parties

For full print and download access, please subscribe at https://www.trellis.law/.

Motion-Secondary: Seneca Insurance Company, Inc. A/S/O Southern States Pavement Markings, Inc. v. Kumho Tire U.S.A., Inc.

Preview

Related Topics

Case Info

Parties