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Charcalla-V.-Goodyear-Tire-Rubber-Co

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Charcalla-V.-Goodyear-Tire-Rubber-Co Case 1:13-cv-00204-JFC Document 132 Filed 10/09/17 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA BRENDA CHARCALLA, individually and as personal representative of the Estate of Gary Charcalla and as guardian of her minor sons, Brock Charcalla and Dalton Civil Action No.: 1:13-cv-00204-JFC Charcalla, Plaintiffs, Te Honorable Joy Flowers Conti, Chief District Judge, presiding. v. THE GOODYEAR TIRE & RUBBER Electronically Filed COMPANY, Defendant. PLAINTIFFS’ RESPONSE OPPOSING THE GOODYEAR TIRE & RUBBER COMPANY’S MOTION FOR PARTIAL SUMMARY JUDGMENT NOW COME Plaintiffs, Brenda Charcalla, Brock Charcalla and Dalton Charcalla—by and through their attorneys—to fle their Plaintiffs’ Response Opposing Te Goodyear Tire & Company’s Motion for Partial Summary Judgment. Plaintiffs respectfully move this Court for entry of the attached (proposed) Order determining that all of Plaintiffs’ Pennsylvania state law claims claims, set forth in Plaintiffs’ First Amended Complaint (ECF No. 19), are ripe for jury determination under Pennsylvania law, to wit: (1) Count I (Negligence for Manufacturing Defect, including all negligent failure to warn claims); (2) Count II (Strict Liability); (3) Count III (Breach of Express Warranty); (4) Count V (Exemplary (Punitive) Damages); and (5) Second Estate Cause of Action (Survival), in the above- captioned matter. In support of this Motion, Plaintiff incorporates by reference Plaintiff’s Brief in Support of Plaintiffs’ Response Opposing Te Goodyear Tire & Company’s Motion for Partial Summary Judgment. Case No. 1:13-cv-00204-JFC (W.D. Pa.) Plaintiff’s Response to Goodyear’s MPSJ Page !1 of !2 Case 1:13-cv-00204-JFC Document 132 Filed 10/09/17 Page 2 of 2 WHEREFORE, premises considered, Plaintiffs respectfully request that this Honorable Court deny Te Goodyear Tire & Company’s Motion for Partial Summary Judgment, with prejudice. Date: October 9, 2017 Respectfully submitted, PRIBANIC & PRIBANIC, LLC By: /s/ Victor H. Pribanic Victor H. Pribanic, Esq. PA Bar ID: #30785 Lead Attorney Christopher G. Buck, Ph.D., Esq.* PA Bar ID: #205265 Associate Attorney *On the Response. (Counsel for Plaintiffs.) Case No. 1:13-cv-00204-JFC (W.D. Pa.) Plaintiff’s Response to Goodyear’s MPSJ Page !2 of !2 Case 1:13-cv-00204-JFC Document 132-1 Filed 10/09/17 Page 1 of 1 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA BRENDA CHARCALLA, individually and Civil Action No.: 1:13-cv-00204-JFC as personal representative of the Estate of Gary Charcalla and as guardian of her Te Honorable Joy Flowers Conti, minor sons, Brock Charcalla and Dalton Chief District Judge, presiding. Charcalla, Plaintiffs, Electronically Filed v. THE GOODYEAR TIRE & RUBBER COMPANY, Defendant. ORDER AND NOW, this __________ day of _____________________________, 2017, upon consideration of Defendant Te Goodyear Tire & Rubber Company’s Motion for Partial Summary Judgment, and Plaintiffs’ response thereto, it is hereby ORDERED and DECREED that the motion is DENIED, with prejudice, and that Plaintiff’s Pennsylvania state law claims are ripe for jury determination under Pennsylvania law. BY THE COURT: _____________________________ Joy Flowers Conti Chief U.S. District Judge Case 1:13-cv-00204-JFC Document 133 Filed 10/09/17 Page 1 of 20 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA BRENDA CHARCALLA, individually and Civil Action No.: 1:13-cv-00204-JFC as personal representative of the Estate of Gary Charcalla and as guardian of her Te Honorable Joy Flowers Conti, minor sons, Brock Charcalla and Dalton Chief District Judge, presiding. Charcalla, Plaintiffs, Electronically Filed v. THE GOODYEAR TIRE & RUBBER COMPANY, Defendant. BRIEF IN SUPPORT OF PLAINTIFFS’ RESPONSE OPPOSING THE GOODYEAR TIRE & RUBBER COMPANY’S MOTION FOR PARTIAL SUMMARY JUDGMENT NOW COME Plaintiffs, Brenda Charcalla, Brock Charcalla and Dalton Charcalla—by and through their undersigned attorneys—to fle their within Brief in Support of Plaintiffs’ Response Opposing Te Goodyear (“Goodyear”) Tire & Rubber Company’s Motion for Partial Summary Judgment (“MPSJ”), in accordance with Local Rules 56.1 and Rule 56 of the Federal Rules of Civil Procedure. Before this Court is Goodyear’s instant Motion for Partial Summary Judgment (ECF No. 127), Proposed Order (ECF No. 127-1), Memorandum of Law (ECF No. 128), and Concise Statement of Facts (ECF No. 128). Also pending before this Court is Goodyear’s Motion for Choice of Law Determination (ECF No. 125), the outcome of which will have direct bearing on the instant MPSJ.1 Genuine issues of material fact raise signifcant jury questions, precluding partial summary judgment, for the reasons that follow. 1 Goodyear’s Proposed Order asks this Court to dismiss Plaintiffs claims for: “All negligent failure to warn claims; (2) Count II of the Amended Complaint (Strict Liability); (3) Count III of the Amended Complaint (Breach of Express Warranty); (4) Count V of the Amended Complaint (Exemplary (Punitive) Damages); and (5) Second Estate Cause of Action (Survival).” (Proposed Order (ECF No. 127-1).) Case No. 1:13-cv-00204-JFC (W.D. Pa.) Brief Opposing Goodyear’s MPSJ Page !1 of !20 Case 1:13-cv-00204-JFC Document 133 Filed 10/09/17 Page 2 of 20 COUNTER-STATEMENT OF FACTS Te Incident: “Plaintiffs’ Responsive Concise Statement of Material Facts in Opposition to Goodyear’s Motion for Partial Summary Judgment” (hereafer “Plaintiffs’ Concise Facts”) fled concurrently with this Brief, sets forth, inter alia, the following facts: Tis lawsuit concerns a single vehicle accident that occurred on July 15, 2011 in New Kent County, Virginia. (Plaintiffs’ Concise Facts, ¶ 1.)2 Te vehicle involved in the accident was a used 2000 Freightliner FL60 truck (“Vehicle”), and it was towing a 2003 Alfa Toyhouse camper. (Plaintiffs’ Concise Facts, ¶ 2.) Te front lef tire sustained a tread separation during the Vehicle’s operation. Te subject tire was a Goodyear G647 all-steel commercial truck tire, a 2003 G647 RSA 245/70R19.5, Load Range G, “bearing original serial #MJ 93 WFAW 0203,” manufactured at Goodyear’s plant in Topeka, Kansas in the 2nd week of 2003. Te Virginia State Police Report states: “Te contributing defect to the crash appeared to be the [front] lef tire which blew out.” (Goodyear, Ex. A, at VASP 05.) (Plaintiffs’ Concise Facts, ¶ 3.) Injury and Death: Afer the front lef tire experienced a tread separation, the driver lost control of the Vehicle. Te Vehicle veered to the lef, exited the highway, and struck three trees before the Vehicle landed on its side. (Plaintiffs’ Concise Facts, ¶ 6.) Mr. Charcalla was killed. One witness testifed that he thought that Mr. Charcalla may still have been alive, although unresponsive. (See Deposition of Edgar Esquivel, 67:5–25; 68:1–25; 69:1–11; 118:5–25; 119:1–25; 120:1–16, attached to Plaintiff’s Appendix as Exhibit 1.) Brenda Charcalla (Gary’s wife), and her sons, Brock Charcalla and Dalton Charcalla, were each traveling in either the Vehicle or Camper at the time of the accident and sustained various injuries. (Plaintiffs’ Concise Facts, ¶ 7.) Brenda 2 Prior to the accident, plaintiffs were vacationing in Virginia, having stayed at Virginia Beach campground for six days. (Plaintiffs’ Concise Facts, ¶ 4.) At the time of the accident, Plaintiffs had just begun their return trip to Erie, Pennsylvania. (Plaintiffs’ Concise Facts, ¶ 5.) Case No. 1:13-cv-00204-JFC (W.D. Pa.) Brief Opposing Goodyear’s MPSJ Page !2 of !20 Case 1:13-cv-00204-JFC Document 133 Filed 10/09/17 Page 3 of 20 Charcalla, Brock Charcalla, and Dalton Charcalla each received medical treatment at the Virginia Commonwealth University Medical Center at Richmond, Virginia. (Plaintiffs’ Concise Facts, ¶ 8.) Purchase of Subject Vehicle/Goodyear Tire: On August 18, 2003, the Vehicle was purchased in Ohio by “Gilby” Kosko, a family friend of the Charcallas and used car dealer, who purchased the Vehicle on the Charcallas’ behalf. (Te Vehicle and subject tire was owned by the “Seller,” i.e. “Fifh Tird Bancorp and/or its affiliates, including Fifh Tird Leasing Company,” as documented in the “Bill of Sale” dated August 18, 2003. (See Goodyear’s Appendix, Exhibit D.)3) Te tire was installed at the time of purchase. (Deposition of Brenda Charcalla, 22:8–19, 49:2–7, relevant excerpts attached to Goodyear’s Appendix as Exhibit B.) Brenda Charcalla testifed that the Freightliner’s front tires were “new” at the time of purchase.4 (See Deposition of Brenda Charcalla, 49:2–25; 50:1–7; 133:19–22, attached to Plaintiff’s Appendix as Exhibit 2.) (Plaintiffs’ Concise Facts, ¶ 9.) In 2005, plaintiffs purchased the Camper in Florida. (Plaintiffs’ Concise Facts, ¶ 10.) During their six (6) years of use, Plaintiffs did not have any operational or mechanical problems with the Vehicle or the Subject Tire. Id. at 23:12–15; 51:6–8. (Plaintiffs’ Concise Facts, ¶ 11.) According to the Affidavit of Jack “Mel” Stein, proprietor of J & C Enterprises, the subject 3 Tat said, the ownership history prior to the Seller’s acquisition of the subject Freightliner is not known, except that that the Freightliner was repossessed and then sold: “Te truck was actually a repossession and it was missing the hitch.” (See Deposition of Brenda Charcalla, 49:17–18, Plaintiff’s Appendix, Exhibit 2.) (Plaintiffs’ Concise Facts, ¶ 12.) If the subject tire “was installed at the time of purchase” as a new tire—as Brenda Charcalla has testifed and further averred by way of her affidavit (see Plaintiff’s Appendix, Exhibit 3)—then the Seller evidently purchased the subject tire, presumably from a Goodyear dealer, prior to installing the two new front tires on the subject Freightliner. (Plaintiffs’ Concise Facts, ¶ 13.) 4 Brenda Charcalla testifed: When my husband, Gary L.
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