Memorandum Points and Authorities

Cal. Super. - 6th Dist.March 30, 2021

Gordon Rees Scully Mansukhani, LLP 275 Battery Streeet, Sulte 2000 San Francisco, CA 94111 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 21 CV381 528 Santa Clara - Civil Electronically Filed by Superior Court of CA, County of Santa Clara, AMANDA E. KOMAN (pro hac vice pending) WILLIAMS & CONNOLLY 725 Twelfth Street, N.W. Washington, D.C. 20005 0n 8/30/2021 2:32 PM Tel: (202) 434-5000 / Fax: (202) 434-5029 Reviewed By: Y. Chavez akoman@wc.com Case #21 CV381 528 J. DOMINIC CAMPODONICO (SBN 188035) Envel°pe' 71681 11 GORDON REES SCULLY MANSUKHANI, LLP 275 Battery Street, Suite 2000 San Francisco, CA 941 11 Tel: (415) 986-5900 / Fax: (415) 986-8054 dcampodonico@grsm.com Attorneys for Defendant/Cross-Defendant TYCO FIRE PRODUCTS, LP SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SANTA CLARA CALIFORNIA MUTUAL INSURANCE COMPANY, INC., CASE NO. 21CV381528 MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF UNOPPOSED APPLICATION FOR ADMISSION OF AMANDA E. KOMAN PROHAC VICE Plaintiff, vs. JOHNSON CONTROLS plc, a foreign public limited company; A TOTAL FIRE PROTECTION COMPANY, INC., a California corporation; and DOES 1 through Accompanying Documents (1) Notice 0fUnopposed Application; (2) Verified Application ofAmanda E. 20, inclusive, Koman (3) Declaration of J. Dominic Defendants. Campodonico; (4) [Proposed] Order A TOTAL FIRE PROTECTION Date: TBD COMPANY, INC., a California corporation, Time: 9:00 a.m. Dept: Cross-Complainant, Judge: vs. Complaint Filed: March 30, 2021 JOHNSON CONTROLS plc, a foreign public limited company; TYCO FIRE PRODUCTS, LP; RED LION HOTELS CORPORATION, doing business as RLH CORPORATION; and MOES 1 through 25, inclusive, Cross-Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) g ) Cross-Complaint Filed: June 16, 2021 ) -1- Y. Ch BVGZ MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF APPLICATION FOR ADMISSION OF AMANDA E. KOMAN PRO HAC VICE Gordon Rees Scully Mansukhani, LLP 275 Battery Streeet, Sulte 2000 San Francisco, CA 94111 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I. INTRODUCTION J. Dominic Campodonico submits this Memorandum of Points and Authorities in Support of Application for Amanda E. Koman Pro Hac Vice to appear as counsel for Defendant/Cross- Defendant Tyco Fire Products, LP. II. ARGUMENT This Court has the discretion t0 allow out-of-state attorneys t0 appear as counsel pro hac vice in this matter. Rule 9.40, subdivision (a) of the California Rules of Court provides that: A person Who is not a member 0f the State Bar 0f California but who is a member in good standing of and eligible t0 practice before the bar of any United States court 0r the highest court in any state and Who has been retained to appear in a particular cause pending in a court of this state, may in the discretion 0f the court be permitted upon written application to appear as counsel pro hac vice, provided that an active member 0f the State Bar of California is associated as attorney 0f record. As set forth in the attached Verified Application ofAmanda E. Koman, Ms. Koman meets the requirements set forth in Rule 9.40, as she is not a resident 0f the State 0f California, and is not a member 0f the California Bar. (Verified Application 0fAmanda E. Koman in Support of Application for Admission ofAmanda E. Koman Pro Hac Vice (“Koman Decl.”), 1] 4.) Ms. Koman is a member in good standing 0f the Bar 0f the District 0f Columbia (Id. at 1] 1 and 5) and is an attorney in the Washington, D.C. office 0f Williams & Connolly LLP. (Id. at 11 1.) She has been retained by Defendant Tyco Fire Products, LP. t0 appear 0n behalf of it in this matter. (Id. at 1] 3.) Ms. Koman does not regularly practice law in California, and is not otherwise engaged in business in California. (Id. at 1] 7) In addition, and as set forth in the attached Declaration of J. Dominic Campodonico, Mr. Campodonico is an active member of the State Bar 0f California, in good standing, and is an attorney 0f record for defendant/cross-defendant. (Declaration of J. Dominic Campodonico in Support of Application for Admission ofAmanda E. Koman Pro Hac Vice 111-) -2- MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF APPLICATION FOR ADMISSION OF AMANDA E. KOMAN PRO HAC VICE Gordon Rees Scully Mansukhani, LLP 275 Battery Streeet, Sulte 2000 San Francisco, CA 94111 A “GNU! 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Ms. Koman’s application therefore meets the requirements of California Rule of Court 9.40. This application was served on the San Francisco office 0f the State Bar 0f California, accompanied by the requisite fee (Id. at 11 5) and Will be properly served on all parties. III. CONCLUSION Based on the foregoing, Tyco Fire Products, LP respectfully requests that the Court grant this application permitting Ms. Koman t0 appear as counsel pro hac vice 0n behalf 0f Defendant/Cross-Defendant in the above-entitled matter. Dated: August 30, 2021 GORDON REES SCULLY MANSUKHANI, LLP By:mfib mminic Cimpodonico Attorneys for Defendant/Cross-Defendant TYCO FIRE PRODUCTS, LP -3- MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF APPLICATION FOR ADMISSION OF AMANDA E. KOMAN PRO HAC VICE 1 2 3 4 5 6 7 8 9 10 m 11 d O H 12 .fi 3 = i a 3' 13 3‘36 g g Q. 14 bfi a E‘ w '5 a b; 15 8 § Ln :2 a a 16 5 '“ w E [a 17 c3 18 19 20 21 22 23 24 25 26 27 12403 14/60096827VJ 28 PROOF OF SERVICE California Mutual Insurance Company v. Johnson Controls plc, et al. Santa Clara County Superior Court, Case N0. 21CIV381528 I am a resident 0f the State of California, over the age 0f 18 years, and not a party to the Within action. My business address is Gordon Rees Scully Mansukhani, LLP, 275 Battery Street, Suite 2000, San Francisco, California 941 1 1. On the date below, I served the within document(s): MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF APPLICATION FOR ADMISSION 0F AMANDA E. KOMAN PRO HAC VICE ONLY BY ELECTRONIC TRANSMISSION: Only by e-mailing the document(s) to the persons at the e-mail address(es) listed based on notice provided on March 16, 2020 that, during the CoronaVil'us (Covid-19) pandemic, this office Will be working remotely, not able t0 send physical mail as usual, and is therefore using only electronic mail. No electronic message 0r other indication that the transmission was unsuccessful was received Within a reasonable time after the transmission. Attorneysfor Plaintiff Attorneysfor Defendant/Cross-complainant California Mutual Insurance Company A Total Fire Protection Company, Inc. Robert E. Wall, Esq. Candice N. Hamant, Esq. THE GRUNSKY LAW FIRM PC Stephanie M. Drenski, Esq. 240 Westgate Drive TYSON & MENDES LLP Watsonville, CA 95076 371 Bel Marin Keys Boulevard, Suite 100 Tel: 83 1-722-2444 Novato, CA 94949 Fax: 83 1-722-6153 Tel: 628-253-5070 rewall@grunsky1aw.com Fax: 4 1 5-785-3 1 65 chamant@tysonmendes.com sdrenski@tysonmendes.com I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on August 30, 2021, at San Francisco, California.VmMwéa Von Weeks -1- PROOF OF SERVICE