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
Jill L. Ryther, Esq., SBN # 266016
Sarah A. Thompson, Esq. SBN #306692
ELECTRONICALLY FILED
RYTHER LAW GROUP SUPERIOR COURT OF CALIFORNIA
40477 Murrleta Hot Sprlngs Rd COUNTY OF SAN BERNARDINO
STE D1, #157 SAN BERNARDINO DISTRICT
Mumetaa CA 92563 1/24/2024 3:10 PM
Phone: 3 10-75 1 -4404
Fax. 310_773_9192 By: Ariel Barajas, DEPUTY
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 JILL L. RYTHER IN
ANIMAL EMERGENEY CLINIC; arid ) SUPPORT 0F PLAINTIFFS’ MOTION
DOES 1— 50, inclusive, ) TO TAX COSTS
)
Defendants‘
) Hearing date: 5/7/24
NNNNNNHHHHHHHHHH
Ul-PUJNHOKOOOQQUI-PUJNHO
) Time: 8:30 am
)
I, JILL L. RYTHER, declare:
1. I am an attorney licensed t0 practice in the State of California and the managing
partner 0f the firm 0f Ryther Law Group, LLP, attorneys 0f record for plaintiffs ILLYA
HARDY, JOHANNA BARLUND HARDY and TOPLINE K9 SERVICES. Imake this
declaration in support 0f the Plaintiffs’ motion t0 strike or tax portions of the costs claimed by
Defendants Grace Rios, DVM and Animal Emergency Clinic in their Memorandum 0f Costs,
1
DECLARATION OF JILL L. RYTHER IN SUPPORT OF PLAINTIFFS’ MOTION TO TAX COST
served upon Plaintiffs 0n 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 t0 the following facts:
2. Prior to the trial, I spoke t0 the Plaintiffs about the need for a court reporter in
case they lost 0n any cause of action about Which they might want t0 appeal.
\DOOQONUI-bUJNb—t
I also discussed
with Plaintiffs the estimated daily cost of a court reporter. The Plaintiffs decided they could not
afford a court reporter.
3. Later that day, I asked my paralegal, Marc Robinson t0 call George Wallace t0
tell Mr. Wallace that our clients were declining a court reporter. Mr. Robinson reported back to
me that Mr. Wallace responded that he might decide to hire a court reporter anyway.
4. As the Court is aware, Mr. Wallace did hire a court reporter. Ihad no part in
making that decision.
5. Neither I nor Marc Robinson (as far as I know) ever had a conversation with Mr.
Wallace to suggest that Plaintiffs would pay for any fees related to a court reporter. In fact, I
spoke With Mr. Wallace again in person in court 0n the day we ordered the jury panel, andI
NNNNNNr—AHr—ir—Ab—Ar—kr—Ar—ir—kr—A
confirmed again that Plaintiffs were unable to pay for any portion 0f any court reporting fees.
Thus, Defendants should be fully responsible for the $25,888.50 listed in the Memorandum 0f
Costs.
Ul-hUJNi—‘OKDOOQQUl-bUJNHO
I declare under penalty 0f perjury that the foregoing is true and correct, and that this
declaration is executed this 24th day of January, 2024, at Menifee, California.
fig
JILL L. RYTHER (declarant)
2
DECLARATION OF JILL L. RYTHER IN SUPPORT OF PLAINTIFFS’ MOTION TO TAX COST
Document Filed Date
January 24, 2024
Case Filing Date
January 27, 2020
Category
Personal Injury Non-Motor Vehicle Unlimited
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Jill L. Ryther, Esq., SBN # 266016 Sarah A. Thompson, Esq. SBN #306692 ELECTRONICALLY FILED RYTHER LAW GROUP SUPERIOR COURT OF CALIFORNIA 40477 Murrleta Hot Sprlngs Rd COUNTY OF SAN BERNARDINO STE D1, #157 SAN BERNARDINO DISTRICT Mumetaa CA 92563 1/24/2024 3:10 PM Phone: 3 10-75 1 -4404 Fax. 310_773_9192 By: Ariel Barajas, DEPUTY 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 JILL L. RYTHER IN ANIMAL EMERGENEY CLINIC; arid ) SUPPORT 0F PLAINTIFFS’ MOTION DOES 1— 50, inclusive, ) TO TAX COSTS ) Defendants‘ ) Hearing date: 5/7/24 NNNNNNHHHHHHHHHH Ul-PUJNHOKOOOQQUI-PUJNHO ) Time: 8:30 am ) I, JILL L. RYTHER, declare: 1. I am an attorney licensed t0 practice in the State of California and the managing partner 0f the firm 0f Ryther Law Group, LLP, attorneys 0f record for plaintiffs ILLYA HARDY, JOHANNA BARLUND HARDY and TOPLINE K9 SERVICES. Imake this declaration in support 0f the Plaintiffs’ motion t0 strike or tax portions of the costs claimed by Defendants Grace Rios, DVM and Animal Emergency Clinic in their Memorandum 0f Costs, 1 DECLARATION OF JILL L. RYTHER IN SUPPORT OF PLAINTIFFS’ MOTION TO TAX COST served upon Plaintiffs 0n 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 t0 the following facts: 2. Prior to the trial, I spoke t0 the Plaintiffs about the need for a court reporter in case they lost 0n any cause of action about Which they might want t0 appeal. \DOOQONUI-bUJNb—t I also discussed with Plaintiffs the estimated daily cost of a court reporter. The Plaintiffs decided they could not afford a court reporter. 3. Later that day, I asked my paralegal, Marc Robinson t0 call George Wallace t0 tell Mr. Wallace that our clients were declining a court reporter. Mr. Robinson reported back to me that Mr. Wallace responded that he might decide to hire a court reporter anyway. 4. As the Court is aware, Mr. Wallace did hire a court reporter. Ihad no part in making that decision. 5. Neither I nor Marc Robinson (as far as I know) ever had a conversation with Mr. Wallace to suggest that Plaintiffs would pay for any fees related to a court reporter. In fact, I spoke With Mr. Wallace again in person in court 0n the day we ordered the jury panel, andI NNNNNNr—AHr—ir—Ab—Ar—kr—Ar—ir—kr—A confirmed again that Plaintiffs were unable to pay for any portion 0f any court reporting fees. Thus, Defendants should be fully responsible for the $25,888.50 listed in the Memorandum 0f Costs. Ul-hUJNi—‘OKDOOQQUl-bUJNHO I declare under penalty 0f perjury that the foregoing is true and correct, and that this declaration is executed this 24th day of January, 2024, at Menifee, California. fig JILL L. RYTHER (declarant) 2 DECLARATION OF JILL L. RYTHER IN SUPPORT OF PLAINTIFFS’ MOTION TO TAX COST