On January 27, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
Hardy, Illya,
Hardy, Johanna Barlund,
Topline K9 Services,
and
Animal Emergency Clinic,
Rios, Dvm, Grace,
for Personal Injury Non-Motor Vehicle Unlimited
in the District Court of San Bernardino County.
Preview
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George M. Wallace -- Cal. Bar N0. 101472
WALLACE, BROWN & SCHWARTZ
S%%EIJR§$YR%FA§§;§E§AUFORNM
AVenue
%£§r§1g€g}gyarengo SAN BERNARDINQ Drsfi'filgo
Pasadena, California 91 101-1504 0U 05 2021
(626) 844-6777; Fax (626) 795—0353
GRACE RIOS, D.V.M.,
Attorneys for Defendants 3y
" ~
'
KOOONOUI-bWNr—A
and ANIMAL EMERGENCY CLINIC DAISY LON, DEPUTY
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
ILLYA HARDY, an individual; Case No.1 CIV DS 2002744
JOHANNA BARLUND HARDY, an
individual; TOPLINE K9 SERVICES, Unlimited Jurisdiction - Claim
Exceeds $25,000
Plaintiffs, [Assignedfor allpurposes t0 the
Honorable Lynn Poncin, Dept. S28]
VS.
Com laint Filed: January 27, 2020
GRACE RIOS, D.V.M., an Individual; Tria Date: December 13, 2021
ANIMAL EMERGENCY CLINIC;
and DOES 1- 50, inclusive, NOTICE OF MOTION TO
BIFURCATE ISSUES FOR TRIAL
AND FOR SEPARATE TRIAL OF
NNNNNNt—Ir—HHr—AHv—Ap—p—p—n
Defendants.
LIABILITY PRIOR TO TRIAL OF
U‘I-fiLAJNHOKOOONQUl-PUJNP—‘O
DAMAGES: MEMORANDUM OF
POINTS AND AUTHORITIES
DATE: November 8, 2021
TIME: 9:00 am.
DEPT.: $28
TO PLAINTIFFS AND TO THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that on the _8t_h day ofNovember, 202 1 ,
at 9:00 am.
0r as soon thereafter as the matter may be heard, in Department “828” of the above—
entitled Court, located at 247 West Third Street, San Bernardino, California,
Notice of Motion to Bifurcate Issues for Trial; Memorandum of
Points and Authorities - 1
. '
.
defendants GRACE RIOS, D.V.M., and ANIMAL EMERGENCY CLH\IIC, and
each 0f them, Will move the Court for an order granting a prior separate trial on
liability before trial on damages issues in this action.
This motion will be made 0n the grounds that a prior separate trial on liability
issues will promote the ends ofjustice, promote judicial economy and convenience
KOOOQQUI-PWNH
0f witnesses. and Will avoid undue prejudice t0 the moving party that may result
from the intermingling of evidence of potentially non-recoverable damages with
evidence going to the precedent issue of liability. This motion is based upon Code
of Civil Procedure §598 and Code 0f Civil Procedure §1048(b).
The motion will be made based 0n this Notice, the accompanying
Memorandum 0f Points and Authorities, the Declaration of George M. Wallace filed
and served concurrently with this Notice, the pleadings and records 0n file in this
action, matters of Which the Court may take judicial notice, and such other oral 0r
documentary matter as may properly be before the Court at the time of hearing.
DATED: October 5, 2021 WALLACE, BROWN & SCHWARTZ
NNNNNNh—lp—tr—tp—tp—Ab—IHD—IHH
Ul-PUJNHOKOOOQQM-‘hWNF—‘O
by George M. Wallace
Attorneys for Defendants GRACE RIOS,
D.V.M., and ANIMAL EMERGENCY
CLINIC
Notice of Motion to Bifurcate Issues for Trial; Memorandum of
Points and Authorities - 2
Document Filed Date
October 05, 2021
Case Filing Date
January 27, 2020
Category
Personal Injury Non-Motor Vehicle Unlimited
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u u George M. Wallace -- Cal. Bar N0. 101472 WALLACE, BROWN & SCHWARTZ S%%EIJR§$YR%FA§§;§E§AUFORNM AVenue %£§r§1g€g}gyarengo SAN BERNARDINQ Drsfi'filgo Pasadena, California 91 101-1504 0U 05 2021 (626) 844-6777; Fax (626) 795—0353 GRACE RIOS, D.V.M., Attorneys for Defendants 3y " ~ ' KOOONOUI-bWNr—A and ANIMAL EMERGENCY CLINIC DAISY LON, DEPUTY SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO ILLYA HARDY, an individual; Case No.1 CIV DS 2002744 JOHANNA BARLUND HARDY, an individual; TOPLINE K9 SERVICES, Unlimited Jurisdiction - Claim Exceeds $25,000 Plaintiffs, [Assignedfor allpurposes t0 the Honorable Lynn Poncin, Dept. S28] VS. Com laint Filed: January 27, 2020 GRACE RIOS, D.V.M., an Individual; Tria Date: December 13, 2021 ANIMAL EMERGENCY CLINIC; and DOES 1- 50, inclusive, NOTICE OF MOTION TO BIFURCATE ISSUES FOR TRIAL AND FOR SEPARATE TRIAL OF NNNNNNt—Ir—HHr—AHv—Ap—p—p—n Defendants. LIABILITY PRIOR TO TRIAL OF U‘I-fiLAJNHOKOOONQUl-PUJNP—‘O DAMAGES: MEMORANDUM OF POINTS AND AUTHORITIES DATE: November 8, 2021 TIME: 9:00 am. DEPT.: $28 TO PLAINTIFFS AND TO THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that on the _8t_h day ofNovember, 202 1 , at 9:00 am. 0r as soon thereafter as the matter may be heard, in Department “828” of the above— entitled Court, located at 247 West Third Street, San Bernardino, California, Notice of Motion to Bifurcate Issues for Trial; Memorandum of Points and Authorities - 1 . ' . defendants GRACE RIOS, D.V.M., and ANIMAL EMERGENCY CLH\IIC, and each 0f them, Will move the Court for an order granting a prior separate trial on liability before trial on damages issues in this action. This motion will be made 0n the grounds that a prior separate trial on liability issues will promote the ends ofjustice, promote judicial economy and convenience KOOOQQUI-PWNH 0f witnesses. and Will avoid undue prejudice t0 the moving party that may result from the intermingling of evidence of potentially non-recoverable damages with evidence going to the precedent issue of liability. This motion is based upon Code of Civil Procedure §598 and Code 0f Civil Procedure §1048(b). The motion will be made based 0n this Notice, the accompanying Memorandum 0f Points and Authorities, the Declaration of George M. Wallace filed and served concurrently with this Notice, the pleadings and records 0n file in this action, matters of Which the Court may take judicial notice, and such other oral 0r documentary matter as may properly be before the Court at the time of hearing. DATED: October 5, 2021 WALLACE, BROWN & SCHWARTZ NNNNNNh—lp—tr—tp—tp—Ab—IHD—IHH Ul-PUJNHOKOOOQQM-‘hWNF—‘O by George M. Wallace Attorneys for Defendants GRACE RIOS, D.V.M., and ANIMAL EMERGENCY CLINIC Notice of Motion to Bifurcate Issues for Trial; Memorandum of Points and Authorities - 2