On October 08, 2020 a
Request,Application
was filed
involving a dispute between
Jacocks Stanley,
Mcdonald Krystol Renee,
Mcdonald Kyira Renee,
and
Fieldturf Usa Inc.,
Wells Robert Aaron,
for Motor Vehicle - Personal Injury/Property Damage/Wrongful Death (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 09/03/2021 11:04 AM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Briggs,Deputy Clerk
1 LEWIS BRISBOIS BISGAARD & SMITH LLP
MATTHEW P. HARRISON, SB# 222073
2 E-Mail: Matthew.Harrison@lewisbrisbois.com
JOHN R. HORSTMANN, SB# 327129
3 E-Mail: John.Horstmann@lewisbrisbois.com
633 West 5th Street, Suite 4000
4 Los Angeles, California 90071
Telephone: 213.250.1800
5 Facsimile: 213.250.7900
6 Attorneys for Defendant
ROBERT AARON WELLS
7
8
SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
COUNTY OF LOS ANGELES
10
MICHAEL ANTONOVICH ANTELOPE VALLEY COURTHOUSE
11
12
BRIANNA MAREESE JACOCKS, a minor Case No. 20AVCV00726
13 by and through her Guardian ad Litem
STANLEY JACOCKS, KATIE FRANCIS DEFENDANT ROBERT AARON WELLS’
14 JACOCKS, a minor by and through her APPLICATION TO BIFURCATE
Guardian ad Litem STANLEY JACOCKS, PROCEEDINGS ON THE AMOUNT OF
15 GENE DAVEYON BERNIE JACOCKS, a ANY PUNITIVE DAMAGES AWARD
minor by and through his Guardian ad Litem UNTIL AFTER A FINDING OF
16 STANLEY JACOCKS, KRYSTOL RENEE ENTITLEMENT TO PUNITIVE
MCDONALD, and KYIRA RENEE DAMAGES
17 MCDONALD,
[Filed with Proposed Order]
18 Plaintiffs,
Assigned for All Purposes to:
19 vs. Hon. Wendy Chang, Dept. A15
20 ROBERT AARON WELLS, FIELDTURF Action Filed: 10/08/2020
USA, INC., and DOES 1 through 30, FSC Date: 09/22/2021
21 inclusive, Trial Date: 10/01/2021
22 Defendants.
23
24 TO THIS HONORABLE COURT, AND TO ALL PARTIES AND THEIR ATTORNEYS
25 OF RECORD:
26 Defendant, ROBERT AARON WELLS (“Defendant”), hereby applies, pursuant to Civil
27 Code section 3295(d), to preclude the admission of evidence concerning the amount of a punitive
28 damages award, including evidence concerning Defendant’s profits or financial condition, until the
LEWIS
BRISBOIS
BISGAARD
& SMITH LLP
4842-7747-6600.1 1
ATTORNEYS AT LAW DEFENDANT ROBERT AARON WELLS’ APPLICATION TO BIFURCATE PUNITIVE DAMAGES
Document Filed Date
September 03, 2021
Case Filing Date
October 08, 2020
Category
Motor Vehicle - Personal Injury/Property Damage/Wrongful Death (General Jurisdiction)
Status
Request for Dismissal - Before Trial not following ADR or more than 60 days since ADR 11/03/2022
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Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 09/03/2021 11:04 AM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Briggs,Deputy Clerk 1 LEWIS BRISBOIS BISGAARD & SMITH LLP MATTHEW P. HARRISON, SB# 222073 2 E-Mail: Matthew.Harrison@lewisbrisbois.com JOHN R. HORSTMANN, SB# 327129 3 E-Mail: John.Horstmann@lewisbrisbois.com 633 West 5th Street, Suite 4000 4 Los Angeles, California 90071 Telephone: 213.250.1800 5 Facsimile: 213.250.7900 6 Attorneys for Defendant ROBERT AARON WELLS 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF LOS ANGELES 10 MICHAEL ANTONOVICH ANTELOPE VALLEY COURTHOUSE 11 12 BRIANNA MAREESE JACOCKS, a minor Case No. 20AVCV00726 13 by and through her Guardian ad Litem STANLEY JACOCKS, KATIE FRANCIS DEFENDANT ROBERT AARON WELLS’ 14 JACOCKS, a minor by and through her APPLICATION TO BIFURCATE Guardian ad Litem STANLEY JACOCKS, PROCEEDINGS ON THE AMOUNT OF 15 GENE DAVEYON BERNIE JACOCKS, a ANY PUNITIVE DAMAGES AWARD minor by and through his Guardian ad Litem UNTIL AFTER A FINDING OF 16 STANLEY JACOCKS, KRYSTOL RENEE ENTITLEMENT TO PUNITIVE MCDONALD, and KYIRA RENEE DAMAGES 17 MCDONALD, [Filed with Proposed Order] 18 Plaintiffs, Assigned for All Purposes to: 19 vs. Hon. Wendy Chang, Dept. A15 20 ROBERT AARON WELLS, FIELDTURF Action Filed: 10/08/2020 USA, INC., and DOES 1 through 30, FSC Date: 09/22/2021 21 inclusive, Trial Date: 10/01/2021 22 Defendants. 23 24 TO THIS HONORABLE COURT, AND TO ALL PARTIES AND THEIR ATTORNEYS 25 OF RECORD: 26 Defendant, ROBERT AARON WELLS (“Defendant”), hereby applies, pursuant to Civil 27 Code section 3295(d), to preclude the admission of evidence concerning the amount of a punitive 28 damages award, including evidence concerning Defendant’s profits or financial condition, until the LEWIS BRISBOIS BISGAARD & SMITH LLP 4842-7747-6600.1 1 ATTORNEYS AT LAW DEFENDANT ROBERT AARON WELLS’ APPLICATION TO BIFURCATE PUNITIVE DAMAGES