On January 27, 2020 a
Complaint,Petition
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.
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SUPERIC
C
RCC IJFiT4F ALIFORNIA
TY
SARi B A AN E ER RRDiNC
Jill L Ryther SBN 266016 p STRIC T
Esq
RYTHER LAW GROUP LLP
2 P 2 4 20 Q
Mailing address P O Box 863
Idyllwild CA 92549
u
3
E Y
Phone 951 468 4045
4 LYIAB Ti i GaM Z EPUTY
Fax 310 773 9192
s
Attorney for Plaint s
6 ILLYA HARDY JOHANNA BARLUND HARDY
TOPLINE K9 SERVICES
SUPERIOR COURT OF CALIFORNIA
8
COUNTY OF SAN BERNADINO
9
io ILLYA HARDY an individual JOHANNA Case No CIV DS 2002744
BARLUND HARDY an individual Honorable Lynn Poncin Dept S28
TOPLINE K9 SERVICES
12
Plaintiffs PLAINTIFFS VERIFIED SECOND
13 AMENDED COMPLAINT FOR
vs
DAMAGES
14
GRACE RIOS DVM an individuai l Negligence 1
s
ANIMAL EMERGENCY CLINIC and 2 Conversion
16
DOES 1 50 Inclusive 3 Breach of Contract
4 Breach of Bailment
i
5 Int r tional Infliction of Emotional
ix Defendants Distress
6 Loss of Profits Economic Damage
19
Complaintfiled i 27 20
20
Trial date none assigned
2t
Unlimited Case Over 25 000 00
Zz
23
I
24
INTRODUCTION
as
26 Plaintiffs herein file this Verified Second Amended Complaint in bringing suit for the
27
wrongful and unlawful death of their beloved family companion and business asset an 18
28
month old Rottweiler named CHAYA VOM HARDY ROTTWEILER and as California law
i
PLANTIFFS VER FIED SECOND AMENDED COMPLAINT FOR DAMAGES
defines their property who was not only a central member of their family but also the most
2
valuable asset of their business operations
II
4
JURISDICTION AND VENUE
5
6 Subject matter and personal jurisdiction are appropriate in this forum because the claims
arose in the City of Grand Terrace County of San Bernadino and all parties have regular
s
ongoing business in the Cities of Grand Terrace or Perris County of Riverside
9
III
10
PARTIES
i2 1 Plaintiffs TOPLINE K9 SERVICES TOPLINE JOHANNA BARLLJND
13
HARDY JOHANNA and ILLYA HARDY ILLYA are now and at all times herein
a
mentioned have been individuals residing or a business operating in the County of Riverside
15
State of California Plaintiffs were the owner of an 18 month old Rottweiler named CHAYA
16
VOM HARDY ROTTWEILER CHAYA
18 2 Defendant ANIMAL EMERGENCY CLINIC hereinafter referred to as
19
Defendant or AEC and Defendant GRACE RIOS DVM hereinafter referred to as
zo
Defendant or RIOS and DOES 1 50 Inclusive hereinafter collectively referred to as
21
22
Defendants are and at all times herein alleged were conducting regular and ongoing
23 business in the City of Grand Terrace County of San Bernadino
24
3 Defendants herein alleged were the agents of their co Defendants and in
2s
committing the acts and omissions herein alleged were acting within the course and scope of
z
such agency with the permission and consent of their co Defendants
2
2s
2
PLANTIFFS VERIFIED SECOND AMENDED COMPLAINT FOR DAMAGES
Document Filed Date
September 24, 2020
Case Filing Date
January 27, 2020
Category
Personal Injury Non-Motor Vehicle Unlimited
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SUPERIC C RCC IJFiT4F ALIFORNIA TY SARi B A AN E ER RRDiNC Jill L Ryther SBN 266016 p STRIC T Esq RYTHER LAW GROUP LLP 2 P 2 4 20 Q Mailing address P O Box 863 Idyllwild CA 92549 u 3 E Y Phone 951 468 4045 4 LYIAB Ti i GaM Z EPUTY Fax 310 773 9192 s Attorney for Plaint s 6 ILLYA HARDY JOHANNA BARLUND HARDY TOPLINE K9 SERVICES SUPERIOR COURT OF CALIFORNIA 8 COUNTY OF SAN BERNADINO 9 io ILLYA HARDY an individual JOHANNA Case No CIV DS 2002744 BARLUND HARDY an individual Honorable Lynn Poncin Dept S28 TOPLINE K9 SERVICES 12 Plaintiffs PLAINTIFFS VERIFIED SECOND 13 AMENDED COMPLAINT FOR vs DAMAGES 14 GRACE RIOS DVM an individuai l Negligence 1 s ANIMAL EMERGENCY CLINIC and 2 Conversion 16 DOES 1 50 Inclusive 3 Breach of Contract 4 Breach of Bailment i 5 Int r tional Infliction of Emotional ix Defendants Distress 6 Loss of Profits Economic Damage 19 Complaintfiled i 27 20 20 Trial date none assigned 2t Unlimited Case Over 25 000 00 Zz 23 I 24 INTRODUCTION as 26 Plaintiffs herein file this Verified Second Amended Complaint in bringing suit for the 27 wrongful and unlawful death of their beloved family companion and business asset an 18 28 month old Rottweiler named CHAYA VOM HARDY ROTTWEILER and as California law i PLANTIFFS VER FIED SECOND AMENDED COMPLAINT FOR DAMAGES defines their property who was not only a central member of their family but also the most 2 valuable asset of their business operations II 4 JURISDICTION AND VENUE 5 6 Subject matter and personal jurisdiction are appropriate in this forum because the claims arose in the City of Grand Terrace County of San Bernadino and all parties have regular s ongoing business in the Cities of Grand Terrace or Perris County of Riverside 9 III 10 PARTIES i2 1 Plaintiffs TOPLINE K9 SERVICES TOPLINE JOHANNA BARLLJND 13 HARDY JOHANNA and ILLYA HARDY ILLYA are now and at all times herein a mentioned have been individuals residing or a business operating in the County of Riverside 15 State of California Plaintiffs were the owner of an 18 month old Rottweiler named CHAYA 16 VOM HARDY ROTTWEILER CHAYA 18 2 Defendant ANIMAL EMERGENCY CLINIC hereinafter referred to as 19 Defendant or AEC and Defendant GRACE RIOS DVM hereinafter referred to as zo Defendant or RIOS and DOES 1 50 Inclusive hereinafter collectively referred to as 21 22 Defendants are and at all times herein alleged were conducting regular and ongoing 23 business in the City of Grand Terrace County of San Bernadino 24 3 Defendants herein alleged were the agents of their co Defendants and in 2s committing the acts and omissions herein alleged were acting within the course and scope of z such agency with the permission and consent of their co Defendants 2 2s 2 PLANTIFFS VERIFIED SECOND AMENDED COMPLAINT FOR DAMAGES