`
`11098
`
`GROTEFELD HOFFMANN, LLP
`VINCENT G. RABOTEAU
`
`vraboteau@ghlaw-llp.com
`Pacific Guardian Center, Makai Tower
`733 Bishop Street, Suite 2070
`Honolulu, Hawaiʻi 96813
`Telephone No.: (808) 458-5060
`Facsimile No.: (312) 551-2402
`
`Counsel for Subrogation Plaintiffs
`(see signature page for full list
`of parties and counsel)
`
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE DISTRICT OF HAWAIʻI
`
`
`
`In RE: Lāhainā Wildfire Litigation
`
`1:24-cv-00259-JAO-BMK
`(Class Action)
`
`SUBROGATION PLAINTIFFS’
`MOTION TO INTERVENE;
`MEMORANDUM IN SUPPORT OF
`MOTION; DECLARATION OF
`NORMAND LEZY;
`DECLARATION OF VINCENT G.
`RABOTEAU; EXHIBITS 1 TO 7;
`CERTIFICATE OF SERVICE
`
`HEARING
`Date:
`Time:
`Judge:
`
`No Trial Date
`
`__________________
`__________________
`Hon. Jill A. Otake
`
`
`
`
`
`
`
`Case 1:24-cv-00259-JAO-WRP Document 21 Filed 09/26/24 Page 2 of 3 PageID.222
`
`SUBROGATION PLAINTIFFS’ MOTION TO INTERVENE
`
`The undersigned Subrogation Plaintiffs respectfully submit this Motion to
`
`
`
`Intervene pursuant to FRCP 24(a)(2) and FRCP 24(b)(1)(B). A copy of the proposed
`
`pleading setting out Subrogation Plaintiffs’ claims is attached as Exhibit 1 to the
`
`Declaration of Vincent G. Raboteau. This motion is supported by the following
`
`memorandum of points and authorities, the accompanying declaration of Vincent G.
`
`Raboteau, any oral argument, and the pleadings on file in this matter.
`
`STATEMENT OF COMPLIANCE
`
`Prior to the filing of this motion, the parties’ counsel met and conferred
`
`pursuant to LR7.8 on September 19, 2024.
`
`DATED: Honolulu, Hawaiʻi, September 26, 2024.
`
`
`
`
`GROTEFELD HOFFMANN
`By: /s/ Vincent G. Raboteau
`VINCENT G. RABOTEAU
`Counsel for Subrogation Plaintiffs
`AMGUARD INSURANCE COMPANY; CONCERT SPECIALTY INSURANCE
`COMPANY; GENERAL CASUALTY COMPANY OF WISCONSIN; THE
`CINCINNATI INSURANCE COMPANY; UNIVERSAL PROPERTY &
`CASUALTY INSURANCE COMPANY; CERTAIN INTERESTED
`UNDERWRITERS AT LLOYD’S SUBSCRIBING TO POLICY PG2203220;
`CERTAIN INTERESTED UNDERWRITERS AT LLOYD’S SUBSCRIBING TO
`POLICY PG2203891; STATE FARM FIRE AND CASUALTY COMPANY;
`STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY;
`HARLEYSVILLE INSURANCE COMPANY OF NEW YORK; ASPEN
`SPECIALTY INSURANCE COMPANY; ALLSTATE FIRE AND CASUALTY
`INSURANCE COMPANY; ALLSTATE INDEMNITY COMPANY; ALLSTATE
`INSURANCE COMPANY; ALLSTATE PROPERTY AND CASUALTY
`INSURANCE COMPANY; ALLSTATE VEHICLE AND PROPERTY
`INSURANCE COMPANY; INTEGON NATIONAL INSURANCE COMPANY;
`
`2
`
`
`
`Case 1:24-cv-00259-JAO-WRP Document 21 Filed 09/26/24 Page 3 of 3 PageID.223
`
`CERTAIN UNDERWRITERS AT LLOYD’S and VARIOUS NON-LLOYD’S
`INSURERS SUBSCRIBING TO POLICIES PIV209015, PIV205089, PIV202904,
`PIV201596, PIV201325, PIV200359, PIV199831, PIV199736, PIV198096,
`PIV195519
`
`3
`
`
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