On March 06, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Hyle, John,
and
Aguilar, Elia M,
Rodriguez, Arianna Athena,
Rodriguez, Arianne Athena,
Rodriguez, David J,
for PI Motor Vehicle
in the District Court of San Bernardino County.
Preview
RIZIO LIPINKSY LAW FIRM PC
Lauren M. VOgt, Bar NO. 326300
ELECTRONICALLY FILED
1V0£t@1‘izi01awfirm-Com SUPERIOR COURT 0F CALIFORNIA
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2677 N 0 rth am S trec t S t e 225
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COUNTY 0F SAN BERNARDINO
SAN BERNARDINO DISTRICT
Santa Ana, CA 92705
.5 Phone: (714)505-2468 1/16/2024 3:41 PM
Facsumle: (714)547-1245
By: Gilberto Villegas, DEPUTY
QGUI
TOOR LAW APC
Puneet Toor
Bar N0. 289893
245 Fischer Ave. Suite D1
Costa Mesa, CA 92626
Phone: (888) 861—8667 Facsimile: (888) 861-8667
Attorneys for Plaintiff, JOHN HYLE
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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COUNTY OF SAN BERNARDINO
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JOHN HYLE, CASE NO.: CIVDSI907037
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Plaintiff, [Hon. Thomas S. Garza, Dept. 827]
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V. NOTICE OF MOTION AND MOTION TO
17 TAX COSTS; MEMORANDUM OF
ARIANNA ATHENA RODRIGUEZ; DAVID POINTS AND AUTHORITIES;
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J. RODRIGUZ; ELIA M. AGUILAR; and DECLARATION OF LAUREN M. VOGT.
19 DOES 1 through 100, inclusive,
Date: March 28, 2024
20 Defendants. Time: 8:30 AM
Dept.: 828
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Complaint Filed: March 6, 2019
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Trial Date: October 23, 2023
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24 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD,
25 PLEASE TAKE NOTICE that on March 28, 2024, at 8:30 a.m., or as soon thereafter as the
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motion may be heard, in Department $28 0f the above entitled Court, Plaintiff, JOHN HYLE,
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Will move the Court t0 strike, tax, and/or limit certain items contained in the Memorandum of
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Motion to Tax Memorandum 0f Costs
Costs submitted by Defendants ARIANA ATHENEA RODRIGUEZ, DAVID J. RODRIGUEZ
and ELIA AGUILAR, hereinafter (“Defendants”.)
Specifically, Plaintiff hereby moves the Court t0 strike Defendants’ Memorandum of Costs
A
in its entirety on the grounds that pursuant to case law they are not the prevailing parties.
QGUI
Alternatively, Plaintiff moves to tax the following costs because the costs are unreasonable and/or
unnecessary and/or not allowed:
8.b. Expert Fees $74,848.00
11. Trial Exhibit Binders & USB $ 6,616.66
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12. Court Reporter Fees $ 1,989.42
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Total unreasonable and/or unnecessary Costs: $83,454.08.
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This Motion is made on the grounds that Defendants are not the prevailing parties and have
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included includes improper and unallowable items in its costs bill and good cause otherwise
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warrants the relief requested.
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16 The Motion Will be based upon this Notice of Motion, the attached Memorandum of Points
17 and Authorities, the attached Declaration of Lauren M. Vogt, and upon such other evidence as the
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court may entertain at the hearing 0n this motion.
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RIZIO LIPINSKY LAW FIRM PC
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/‘,
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Dated: January 16, 2024 §‘12L\+‘&fé-~x
22 l-LAUREN M. V-G’GT
Attorney for Plaintiff,
23 JOHN HYLE
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Motion to Tax Memorandum 0f Costs
Document Filed Date
January 16, 2024
Case Filing Date
March 06, 2019
Category
PI Motor Vehicle
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