On October 05, 2018 a
Request,Application
was filed
involving a dispute between
Hill, Lisa,
and
Quaid Harley-Davidson, Inc. A California Corporation,
for Business Tort/Unfair Business Practice Unlimited
in the District Court of San Bernardino County.
Preview
H
ORrGINAL
DYKEMA GOSSETT LLP
PAUL L. NYSTROM (Pro Hac Vice)
pnystrom @dykema. com
ABIRAMI GNANADESIGAN, SBN 263375 F I L H. '0
crummu
sur-ERIOR COURT 0F
AGnanadesigan@dykema.com COUNTY 0F SAN BERNARDINO
JONATHAN KAMA (Pro Hac Vice) a»: mNARDND DISTRET
jkama@dykema.c0m
444 South Flower Street, Suite 2200 iUN 1 4 2023
Los Angeles, California 90071
\DOONOU'IAUJNH
Telephone: (2 1 3) 457-1 800 "’"‘ a"
Facsimile: (213) 457-1850 BY
ANTHONY fv' rim mafia? UTY
FAX
Attorneys for Cross-Defendant, HARLEY-
DAVIDSON MOTOR COMPANY, INC.
BY
SUPERIOR COURT 0F THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT
90071
LLP
AVENUE
CALIFORNIA
LISA HILL, an individual Case No. CIVDS 1 826573
GOSSETT 2100
GRAND
Plaintiff, Assigned to Hon. Wilfred J. Schneider, Jr.
SUITE
Dept. $32
SOUTH
ANGELES,
V.
DYKEMA
333
Los
QUAID HARLEY-DAVIDSON, INC, a
California Corporation, and DOES through 1 REQUEST FOR JUDICIAL NOTICE IN
10, inclusive,, SUPPORT OF CROSS-DEFENDANT
NNNNNNNNNt—KHh—t—tt—dp—th—Hp—‘y—a
HARLEY-DAVIDSON MOTOR
Defendant. COMPANY, INC.’S REPLY FOR
DEMURRER TO SECOND AMENDED
CROSS-COMPLAINT
QUAID HARLEY-DAVIDSON,
OONONUI#WNHO\OOO\IOM&WNHO
INC., a
California Corporation, Date: June 22, 2023
Time: 8:30 A.M.
Cross-Complainant, Dept: S32
v.
HARLEY-DAVIDSON MOTOR
COMPANY, INC., a Wisconsin corporation,
and ROES 1 through 10, inclusive,
Cross-Defendants.
4833—6129-509 l .1 l
REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF REPLY FOR DEMURRER TO SECOND AMENDED CROSS-COMPLAINT
pl
Pursuant t0 Section 452 of the California Evidence Code and California Rules of Coutt
rules 3.1 1 13 and 3.1306, Cross-Defendant Harley-Davidson Motor Company, Inc. (“Harley-
Davidson”), by and through counsel of record, respectfully requests that the Court take judicial
ka notice of the following documents attached hereto as Exhibits A through D, filed in support of
Harley-Davidson’s Reply for its Demurrer to the Second Amended Cross-Complaint:
1. Demurrer t0 Amended Cross-Complaint filed by Harley-Davidson in the above-
captioned matter, a true and correct copy of which is attached hereto as Exhibit A.
\DOO\IO\
2. Quaid Harley-Davidson, Inc.’s Opposition to the Demurrer to the Amended Cross-
Complaint, a true and correct copy of which is attached hereto as Exhibit B.
10 3. This Court’s ruling on Harley-Davidson’s Demurrer to the Amended Cross-
11 Complaint, a true and correct copy of which is attached hereto as Exhibit C.
90071
LLP
12 4. Quaid Harley-Davidson, Inc’s Amended Cross—Complaint, a true and correct copy
AVENUE
CALIFORNIA
13 of which is attached hereto as Exhibit D.
GOSSETT 2100
GRAND
14 California Evidence Code section 452 authorizes the Court to take judicial notice of
SUITE
SOUTH
ANGELES,
15 “[fjacts and propositions that are not reasonably subject to dispute and are capable 0f immediate
DYKEMA
333
16 and accurate determination by resort t0 sources of reasonably indisputable accuracy.” Evid. Code,
Los
17 §452(h). Harley-Davidson respectfully requests that the Court take judicial notice of the
18 documents attached hereto as Exhibits A-D because they are matters of public record and capable
19 of accurate and ready determination by resort t0 sources whose accuracy cannot be reasonably
20 questioned. These documents also fall within the ambit of Evidence Code § 452(d) as records of
21 the U.S. Courts.
22 Dated: June 14, 2023 DYKEMA GOSSETT LLP
23
24
Abirami Gnanadesigan
25 Attorneys for Cross-Defendant
HARLEY-DAVIDSON MOTOR
26
COMPANY, INC.
27
28
4833-6129-5091.1 2
REQUEST FOR JUDICIAL NOTICE IN SUPPORT 0F REPLY FOR DEMURRER T0 SECOND AMENDED CROSS-COMPLAINT
Document Filed Date
June 14, 2023
Case Filing Date
October 05, 2018
Category
Business Tort/Unfair Business Practice Unlimited
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H ORrGINAL DYKEMA GOSSETT LLP PAUL L. NYSTROM (Pro Hac Vice) pnystrom @dykema. com ABIRAMI GNANADESIGAN, SBN 263375 F I L H. '0 crummu sur-ERIOR COURT 0F AGnanadesigan@dykema.com COUNTY 0F SAN BERNARDINO JONATHAN KAMA (Pro Hac Vice) a»: mNARDND DISTRET jkama@dykema.c0m 444 South Flower Street, Suite 2200 iUN 1 4 2023 Los Angeles, California 90071 \DOONOU'IAUJNH Telephone: (2 1 3) 457-1 800 "’"‘ a" Facsimile: (213) 457-1850 BY ANTHONY fv' rim mafia? UTY FAX Attorneys for Cross-Defendant, HARLEY- DAVIDSON MOTOR COMPANY, INC. BY SUPERIOR COURT 0F THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT 90071 LLP AVENUE CALIFORNIA LISA HILL, an individual Case No. CIVDS 1 826573 GOSSETT 2100 GRAND Plaintiff, Assigned to Hon. Wilfred J. Schneider, Jr. SUITE Dept. $32 SOUTH ANGELES, V. DYKEMA 333 Los QUAID HARLEY-DAVIDSON, INC, a California Corporation, and DOES through 1 REQUEST FOR JUDICIAL NOTICE IN 10, inclusive,, SUPPORT OF CROSS-DEFENDANT NNNNNNNNNt—KHh—t—tt—dp—th—Hp—‘y—a HARLEY-DAVIDSON MOTOR Defendant. COMPANY, INC.’S REPLY FOR DEMURRER TO SECOND AMENDED CROSS-COMPLAINT QUAID HARLEY-DAVIDSON, OONONUI#WNHO\OOO\IOM&WNHO INC., a California Corporation, Date: June 22, 2023 Time: 8:30 A.M. Cross-Complainant, Dept: S32 v. HARLEY-DAVIDSON MOTOR COMPANY, INC., a Wisconsin corporation, and ROES 1 through 10, inclusive, Cross-Defendants. 4833—6129-509 l .1 l REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF REPLY FOR DEMURRER TO SECOND AMENDED CROSS-COMPLAINT pl Pursuant t0 Section 452 of the California Evidence Code and California Rules of Coutt rules 3.1 1 13 and 3.1306, Cross-Defendant Harley-Davidson Motor Company, Inc. (“Harley- Davidson”), by and through counsel of record, respectfully requests that the Court take judicial ka notice of the following documents attached hereto as Exhibits A through D, filed in support of Harley-Davidson’s Reply for its Demurrer to the Second Amended Cross-Complaint: 1. Demurrer t0 Amended Cross-Complaint filed by Harley-Davidson in the above- captioned matter, a true and correct copy of which is attached hereto as Exhibit A. \DOO\IO\ 2. Quaid Harley-Davidson, Inc.’s Opposition to the Demurrer to the Amended Cross- Complaint, a true and correct copy of which is attached hereto as Exhibit B. 10 3. This Court’s ruling on Harley-Davidson’s Demurrer to the Amended Cross- 11 Complaint, a true and correct copy of which is attached hereto as Exhibit C. 90071 LLP 12 4. Quaid Harley-Davidson, Inc’s Amended Cross—Complaint, a true and correct copy AVENUE CALIFORNIA 13 of which is attached hereto as Exhibit D. GOSSETT 2100 GRAND 14 California Evidence Code section 452 authorizes the Court to take judicial notice of SUITE SOUTH ANGELES, 15 “[fjacts and propositions that are not reasonably subject to dispute and are capable 0f immediate DYKEMA 333 16 and accurate determination by resort t0 sources of reasonably indisputable accuracy.” Evid. Code, Los 17 §452(h). Harley-Davidson respectfully requests that the Court take judicial notice of the 18 documents attached hereto as Exhibits A-D because they are matters of public record and capable 19 of accurate and ready determination by resort t0 sources whose accuracy cannot be reasonably 20 questioned. These documents also fall within the ambit of Evidence Code § 452(d) as records of 21 the U.S. Courts. 22 Dated: June 14, 2023 DYKEMA GOSSETT LLP 23 24 Abirami Gnanadesigan 25 Attorneys for Cross-Defendant HARLEY-DAVIDSON MOTOR 26 COMPANY, INC. 27 28 4833-6129-5091.1 2 REQUEST FOR JUDICIAL NOTICE IN SUPPORT 0F REPLY FOR DEMURRER T0 SECOND AMENDED CROSS-COMPLAINT