Preview
°
Esq" SEN # 266016
J1“ L' Ryther’ ELECTRONICALLY FILED
SUPERIOR COURT 0F CALIFORNIA
Sarah A. Thompson, Esq. SBN #306692 COUNTY OF SAN BERNARDINO
RYTHER LAW GROUP SAN BERNARDINO DISTRICT
40477 Murrieta Hot Springs Rd
1/24/2024 3.38
_
PM
STE D1, #157
Murrieta, CA 92563 By: Sergio Villanueva, DEPUTY
Phone: 3 10-75 1 -4404
Fax: 3 10-773-9 1 92
KOOOQONUI-PUJNH
Attorneysfor Plaintifls,
JOHANNA BARLUND, ILLYA HARDY
TOPLINE K9 SERVICES
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
ILLYA HARDY, an individual; JOHANNA ) Case N0. CIV DS 2002744
BARLUND HARDY, an individual; ) Dept S28
TOPLINE K9 SERVICES,
)
Plaintiffs, ) Notice of Entry of Judgment: December 11,
) 2023
vs.
)
GRACE RIOS, D.V.M., an Individual; ) DECLARATION OF MARC ROBINSON
ANIMAL EMERGENCY CLINIC; and ) IN SUPPORT OF PLAINTIFFS’ MOTION
DOES 1— 50, inclusive, ) TO TAX COSTS
)
Defendants‘
) Hearing date: 5/7/24
NNNNNNHHHHHHHHHH
Ul-PUJNHOKOOOQQUI-PUJNHO
) Time: 8:30 am
)
I, MARC ROBINSON, declare:
1. I am a paralegal working as an independent contractor on specified cases for
Ryther Law Group LLP (Which, at the time 0f the trial was Ryther Law Group), attorneys of
record for plaintiffs ILLYA HARDY, JOHANNA BARLUND HARDY and TOPLINE K9
SERVICES. I make this declaration in support 0f the Plaintiffs’ motion t0 strike or tax portions
0f the costs claimed by Defendants Grace Rios, DVM and Animal Emergency Clinic in their
1
DECLARATION OF MARC ROBINSON IN SUPPORT OF PLAINTIFFS’ MOTION TO TAX COST
Memorandum 0f Costs, served upon Plaintiffs on January 4, 2024, but not appearing online as
filed With the Court. The facts contained in this declaration are personally known to me unless
otherwise stated. If called upon t0 testify under oath, I could and would competently testify to the
following facts:
2. Prior t0 the trial, I spoke to Jill Ryther Who told me she had spoken t0 the
KOOOQONUI-PUJNH
Plaintiffs about the need for a court reporter. She told me the Plaintiffs decided they could not
afford a court reporter. She then asked me t0 call Mr. Wallace and notify him that Plaintiffs
would be declining a court reporter.
3. Later that day, I spoke by phone t0 George Wallace and explained that our clients
were declining a court reporter. Mr. Wallace responded that he might decide t0 hire a court
reporter anyway.
4. I never had a conversation with Mr. Wallace t0 suggest that Plaintiffs would pay
for any fees related to a court reporter.
5. Per Jill Ryther’s request, and in coordination With George Wallace, I submitted a
request for a hearing on this motion and listed three dates. On January 23, 2024, I received an
email from the SBJC Civil Motion Reservation Request department that read, “Thank you for
your email. Unfortunately the dates you have requested are not available. Please submit 3 new
NNNNNNHHHHHHHHHH
Ul-PUJNHOKOOOQQUI-PUJNHO
dates starting 4/3 0/24. We apologize for any inconvenience this may cause.” It was signed “AR.”
Thus, as of the filing 0f this motion, we d0 not have a reservation. I Will be coordinating with
both Counsels on January 24, 2024 t0 select three new possible dates.
6. After I sent in three new possible dates, I received a response, 0n January 24,
2024, stating in part, “Your motion date is 5/7/2024 at @am in department fl.” After
notifying Jill Ryther, she directed me t0 refile, 0n January 24, 2024, the motion, her declaration,
and my declaration.
//
2
DECLARATION OF MARC ROBINSON IN SUPPORT OF PLAINTIFFS’ MOTION TO TAX COST
Preview
° Esq" SEN # 266016 J1“ L' Ryther’ ELECTRONICALLY FILED SUPERIOR COURT 0F CALIFORNIA Sarah A. Thompson, Esq. SBN #306692 COUNTY OF SAN BERNARDINO RYTHER LAW GROUP SAN BERNARDINO DISTRICT 40477 Murrieta Hot Springs Rd 1/24/2024 3.38 _ PM STE D1, #157 Murrieta, CA 92563 By: Sergio Villanueva, DEPUTY Phone: 3 10-75 1 -4404 Fax: 3 10-773-9 1 92 KOOOQONUI-PUJNH Attorneysfor Plaintifls, JOHANNA BARLUND, ILLYA HARDY TOPLINE K9 SERVICES SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO ILLYA HARDY, an individual; JOHANNA ) Case N0. CIV DS 2002744 BARLUND HARDY, an individual; ) Dept S28 TOPLINE K9 SERVICES, ) Plaintiffs, ) Notice of Entry of Judgment: December 11, ) 2023 vs. ) GRACE RIOS, D.V.M., an Individual; ) DECLARATION OF MARC ROBINSON ANIMAL EMERGENCY CLINIC; and ) IN SUPPORT OF PLAINTIFFS’ MOTION DOES 1— 50, inclusive, ) TO TAX COSTS ) Defendants‘ ) Hearing date: 5/7/24 NNNNNNHHHHHHHHHH Ul-PUJNHOKOOOQQUI-PUJNHO ) Time: 8:30 am ) I, MARC ROBINSON, declare: 1. I am a paralegal working as an independent contractor on specified cases for Ryther Law Group LLP (Which, at the time 0f the trial was Ryther Law Group), attorneys of record for plaintiffs ILLYA HARDY, JOHANNA BARLUND HARDY and TOPLINE K9 SERVICES. I make this declaration in support 0f the Plaintiffs’ motion t0 strike or tax portions 0f the costs claimed by Defendants Grace Rios, DVM and Animal Emergency Clinic in their 1 DECLARATION OF MARC ROBINSON IN SUPPORT OF PLAINTIFFS’ MOTION TO TAX COST Memorandum 0f Costs, served upon Plaintiffs on January 4, 2024, but not appearing online as filed With the Court. The facts contained in this declaration are personally known to me unless otherwise stated. If called upon t0 testify under oath, I could and would competently testify to the following facts: 2. Prior t0 the trial, I spoke to Jill Ryther Who told me she had spoken t0 the KOOOQONUI-PUJNH Plaintiffs about the need for a court reporter. She told me the Plaintiffs decided they could not afford a court reporter. She then asked me t0 call Mr. Wallace and notify him that Plaintiffs would be declining a court reporter. 3. Later that day, I spoke by phone t0 George Wallace and explained that our clients were declining a court reporter. Mr. Wallace responded that he might decide t0 hire a court reporter anyway. 4. I never had a conversation with Mr. Wallace t0 suggest that Plaintiffs would pay for any fees related to a court reporter. 5. Per Jill Ryther’s request, and in coordination With George Wallace, I submitted a request for a hearing on this motion and listed three dates. On January 23, 2024, I received an email from the SBJC Civil Motion Reservation Request department that read, “Thank you for your email. Unfortunately the dates you have requested are not available. Please submit 3 new NNNNNNHHHHHHHHHH Ul-PUJNHOKOOOQQUI-PUJNHO dates starting 4/3 0/24. We apologize for any inconvenience this may cause.” It was signed “AR.” Thus, as of the filing 0f this motion, we d0 not have a reservation. I Will be coordinating with both Counsels on January 24, 2024 t0 select three new possible dates. 6. After I sent in three new possible dates, I received a response, 0n January 24, 2024, stating in part, “Your motion date is 5/7/2024 at @am in department fl.” After notifying Jill Ryther, she directed me t0 refile, 0n January 24, 2024, the motion, her declaration, and my declaration. // 2 DECLARATION OF MARC ROBINSON IN SUPPORT OF PLAINTIFFS’ MOTION TO TAX COST