On February 14, 2019 a
Application for Determination of Good Faith Settlement
was filed
involving a dispute between
Inner Gardens Inc.,
Saks Wayne J,
and
Beverly Spalding Court Homeowners' Association,
Gelfond Frederick "Gordon",
Inner Gardens Inc.,
Jone Earl "Richie",
Landi Pascal,
Pink Jeffrey Z,
Pink Jeff Z,
for civil
in the District Court of Los Angeles County.
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Electronically FILED by Superior Court of California, County of Los Angeles on 08/18/2022 03:29 PM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Mariscal,Deputy Clerk
R2 LAW GROUP, LLP
ADAM J. SOIBELMAN, State Bar No.: 150106
ASoibelman@R2Law Group. corn
ROBIN MCCONNELL, State Bar No.: 190247
RMcConnell@R2LawGroup.corn
23901 Calabasas Road, Suite 2006
Calabasas, CA 91302
Telephone: (818) 610-3222
Facsimile: (818) 610-3322
Attorneys for Defendant/Cross-Complainant,
INNER GARDENS, INC., a California corporation
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES, WEST DISTRICT
10
WAYNE J. SAKS, et al. Lead Case No.: 19SMCV00289
[Consolidated with Case No. 19SMCV01637]
Plaintiffs, (Complaint Filed: February 14,
12 for all Purposes to the
2019'Assigned
vs. Honorable Mark A. Young, Dept. Mf
Ct f4 13
t4
dl
O A JEFFREY Z. PINK, an individual; et al. DEFENDANT INNER GARDENS, INC.'S
14 APPLICATION FOR DETERMINATION
cR
'0
Defendants. OF GOOD FAITH SETTLEMENT;
CI g g~ 15 DECLARATION OF ROBIN
Ce tn MCCONNELL IN SUPPORT THEREOF
U AND RELATED CROSS-ACTIONS.
E 16
[Served concurrently with Notice of Settlement
17 and Proposed Order]
~ I
CV 18
19 TO THE COURT AND TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD HEREIN:
20 PLEASE TAKE NOTICE that Defendant/Cross-Complainant, INNER GARDENS, INC.,
21 through its attorneys of record herein, hereby applies to this Court, pursuant to Code of Civil
22 Procedure $ 877.6 subd. (a)(2) for an order determining that the settlement between Inner
23 Gardens, on the one hand, and Plaintiffs, WAYNE J. SAKS, an individual, and WAYNEJ. SAKS,
24 Trustee of the WAYNE J. SAKS TRUST OF 2001, on the other hand, was made in good faith,
25 and requests an order that any existing, pending, and future claims for equitable comparative
26 contribution, or total, partial and comparative indemnity, against Inner Gardens based on
27 comparative negligence or comparative fault be dismissed and forever barred.
28 ///
DEFENDANT INNER GARDENS, INC.'S APPLICATION FOR DETERMINATION OF GOOD FAITH
SETTLEMENT
Document Filed Date
August 18, 2022
Case Filing Date
February 14, 2019
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Electronically FILED by Superior Court of California, County of Los Angeles on 08/18/2022 03:29 PM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Mariscal,Deputy Clerk R2 LAW GROUP, LLP ADAM J. SOIBELMAN, State Bar No.: 150106 ASoibelman@R2Law Group. corn ROBIN MCCONNELL, State Bar No.: 190247 RMcConnell@R2LawGroup.corn 23901 Calabasas Road, Suite 2006 Calabasas, CA 91302 Telephone: (818) 610-3222 Facsimile: (818) 610-3322 Attorneys for Defendant/Cross-Complainant, INNER GARDENS, INC., a California corporation SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES, WEST DISTRICT 10 WAYNE J. SAKS, et al. Lead Case No.: 19SMCV00289 [Consolidated with Case No. 19SMCV01637] Plaintiffs, (Complaint Filed: February 14, 12 for all Purposes to the 2019'Assigned vs. Honorable Mark A. Young, Dept. Mf Ct f4 13 t4 dl O A JEFFREY Z. PINK, an individual; et al. DEFENDANT INNER GARDENS, INC.'S 14 APPLICATION FOR DETERMINATION cR '0 Defendants. OF GOOD FAITH SETTLEMENT; CI g g~ 15 DECLARATION OF ROBIN Ce tn MCCONNELL IN SUPPORT THEREOF U AND RELATED CROSS-ACTIONS. E 16 [Served concurrently with Notice of Settlement 17 and Proposed Order] ~ I CV 18 19 TO THE COURT AND TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD HEREIN: 20 PLEASE TAKE NOTICE that Defendant/Cross-Complainant, INNER GARDENS, INC., 21 through its attorneys of record herein, hereby applies to this Court, pursuant to Code of Civil 22 Procedure $ 877.6 subd. (a)(2) for an order determining that the settlement between Inner 23 Gardens, on the one hand, and Plaintiffs, WAYNE J. SAKS, an individual, and WAYNEJ. SAKS, 24 Trustee of the WAYNE J. SAKS TRUST OF 2001, on the other hand, was made in good faith, 25 and requests an order that any existing, pending, and future claims for equitable comparative 26 contribution, or total, partial and comparative indemnity, against Inner Gardens based on 27 comparative negligence or comparative fault be dismissed and forever barred. 28 /// DEFENDANT INNER GARDENS, INC.'S APPLICATION FOR DETERMINATION OF GOOD FAITH SETTLEMENT