of the Superior Court .1 7 RateMyHorsePRO Notice of... · DEFENDANT MARK ARBALLO'S NOTICE OF DEMURRER AND DEMURRER TO ... [Filed Concurrently with Notice of Motion and Motion to Strike;

I',40V 17:14*

Regan Furcolo, Esq. (SBN 162956) Ashley W. Christensen, Esq. (SBN 265171) WALSH MCKEAN FURCOLO LLP 550 West C Street, Suite 950 San Diego, CA 92101 Telephone: (619) 232-8486 Facsimile: (619) 232-2691 rfUrcolora)wm111p.com achristensenrcii WM tlIp.com

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P• Clerk of the Superior Court

NOV .1 7 2014

Attorneys for Defendants MARK ARBALLO, an individual dba ARBALLO REINING HORSES; PATRICIA HOHL, an individual dba ARBALLO REINING HORSES

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9 SUPERIOR COURT OF THE STATE OF CALIFORNIA

10 FOR THE COUNTY OF SAN DIEGO - CENTRAL DIVISION

CASE NO. 37-2014-00032892-CU-PO-CTL

JUDGE: Hon. Joan M. Lewis DEPT.: C-65

DEFENDANT MARK ARBALLO'S NOTICE OF DEMURRER AND DEMURRER TO PLAINTIFFS MARTHA TORKINGTON'S AND RIVER VALLEY RANCH, LLC'S COMPLAINT

[Filed Concurrently with Notice of Motion and Motion to Strike; Request for Judicial Notice in Support Thereof; and [Proposed] Orders Thereon]

Date: February 27, 2015 Time: 8:30 a.m. Dept.: C-65 Judge: Hon. Joan M. Lewis

COMPLAINT FILED: September 26. 2014 FR1A1, DATE: TBD

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MARTIIA TORKINGTON, an individual; and RIVER VALLEY RANCH, LLC, a California limited liability company;

Plaintiffs,

Vs.

MARK ARBALLO, an individual dba Arballo Reining Horses: PATRICIA HOHI„ an individual dba Arballo Reining Horses; and DOES 1 through 100, inclusive,

Defendants.

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TO ALL PARTIES AND THEIR COUNSEL OF RECORD:

PLEASE TAKE NOTICE that on February 27, 2015 at 8:30 a.m., or as soon thereafter

as the matter may be heard, in Department C-65 of the above-entitled court, located at 330 W.

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NITA DANT MARK ARBALLO'S NOTICE OF DEMURRER AND DEMURRER TO PLAINTIFFS MARTHA TORKINGTON'S AND RIVER VALLEY RANCH, LLC'S COMPLAINT

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Broadway, San Diego, CA 92101, the Honorable Joan M. Lewis presiding, the court will hear

the demurrer of Defendant MARK ARBALLO. The demurrer is based upon this notice, the

demurrer, the attached memorandum of points and authorities, the request for judicial notice, and

the pleadings, papers and records on file with the Court herein, and upon such oral and

documentary evidence as may be presented at the hearing of this demurrer.

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7 DATED: November 17, 2014 WALSH MCKEAN FURCOLO LLP

By: Re6n1 rcolo, Esq. Ashley W. Christensen, Esq. Attorneys for Defendants MARK ARBALLO, an individual dba ARBALLO REINING HORSES; PATRICIA HOHL, an individual dba ARBALLO REINING HORSES

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28 WALSH MCKEAN FLIRCOLOCIP

550 WE SIC MEET SUITE 950

SAN DIEGO, CALIFORNIA 92101

TELEPHONE (619) 232-8456

2 DEFENDANT MARK ARBALLO'S NOTICE OF DEMURRER AND DEMURRER TO PLAINTIFFS MARTHA

TORICINGTON'S AND RIVER VALLEY RANCH, LLC'S COMPLAINT


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DEMURRER TO PLAINTIFFS' COMPLAINT

Defendant MARK ARBALLO ("ARBALLO") hereby demurs to the complaint of

Plaintiff MARTHA TORKINGTON and RIVER VALLEY RANCH, LLC (hereinafter

"Plaintiffs") on the grounds that:

1. Plaintiffs' "negligence per se" cause of action against Defendant ARBALLO is

fatally uncertain pursuant to California Code of Civil Procedure §430.10(f).

2. Plaintiffs' complaint does not state facts sufficient to constitute a cause of action

for "negligence per se" against Defendant ARBALLO pursuant to California Code of Civil

Procedure §430.10(e).


for "Gross Negligence, Recklessness and Willful Misconduct" against Defendant ARBALLO

pursuant to California Code of Civil Procedure §430.10(e).

4. Plaintiffs' trespass to chattels cause of action against Defendant ARBALLO is

fatally uncertain pursuant to California Code of Civil Procedure §430.10(0.


for intentional infliction of emotional distress against Defendant ARBALLO pursuant to

California Code of Civil Procedure §430.10(e).

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19 DATED: Ndvember 17, 2014 WALSH MCKEAN FURCOLO LLP

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By: difra Ir Reb"urcolo, Esq.

As ley W. Christensen, Esq. Attorneys for Defendants MARK ARBALLO, an individual dba ARBALLO REINING HORSES; PATRICIA HOHL, an individual dba ARBALLO REINING HORSES

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TORKINGTON'S AND RIVER VALLEY RANCH, LLC'S COMPLAINT

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28 WALSH MCKEAN FURCOLO LIP

550 WE STC STREET SUITE 950

SPA DIEGO, CALIFORMA 92101

TELEPHONE (619)23243486


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MEMORANDUM OF POINTS AND AUTHORITIES

I. INTRODUCTION

Plaintiffs Martha Torkington and River Valley Ranch, LLC ("RVR") bring claims against

Defendant Mark Arballo arising from the unfortunate injury to, and ultimate euthanizing of, Ms.

Torlcington's horse, Bella Gunnabe Gifted ("Bella"). Plaintiffs do not allege specifically how

Bella was injured, other than that she was tied up by Defendants using a specific training

technique and then later found injured. Nevertheless, Plaintiffs now bring claims of negligence,

negligence per se, trespass to chattels, conversion, and intentional infliction of emotional distress

against Mr. Arballo.

Mr. Arballo demurs to Plaintiffs' allegations of negligence per se pursuant to California

Code of Civil Procedure section §430.10(e) and (f) on the grounds that Plaintiffs fail to state a

cause of action for negligence per se and their allegations are uncertain because negligence per

se is not a separate cause of action. Mr. Arballo further demurs to Plaintiffs' negligenceper se

claim pursuant to CCP §430.10(e) on the grounds that Plaintiffs cannot, as a matter of law,

establish that they are within the class of persons Penal Code section 597 is intended to protect,

and they therefore cannot use Penal Code section 597 to establish a standard of care for their

negligence claim in any event.

Mr. Arballo also demurs to Plaintiffs' claim of "Gross Negligence, Recklessness and

Willful Misconduct" pursuant to Code of Civil Procedure section §430.10(e) on the grounds that

Plaintiffs have not alleged the specific elements required to establish any of these claims.

Mr. Arballo also demurs to Plaintiffs' claim for trespass to chattels pursuant to Code of

Civil Procedure section §430.10(f) on the grounds that Plaintiffs' complaint is uncertain because

it alleges the complete dispossession of property, which does not support a claim for trespass to

chattels.

Finally, Mr. Arballo demurs to Plaintiff Torkington's claim for intentional infliction of

emotional distress pursuant to Code of Civil Procedure section §430.10(e) on the grounds that

Ms. Torkington fails to state a cause of action because the conduct complained of was primarily

directed at Bella, not Ms. Torkington and because Ms. Torkington admits that she was not

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550 WEST C STREET SUITE 950

SAN DIEGO. CALIFORNV, 92101

TELEPHONE (619)232-8496




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present when the alleged conduct occurred. Therefore, she has not, and cannot, state a cause of

action for intentional infliction of emotional distress.

II. SUMMARY OF THE FACTS

Plaintiffs allege that around February 2011, Defendants Arballo and Hohl entered into an

agreement with RVR to operate their business, Arballo Reining Horses, on RVR's premises.

(Plaintiffs' Complaint which is attached as Exhibit "A" to the Request for Judicial Notice filed

concurrently herewith at 3:19-21.) Defendants were allegedly provided a place to live on the

ranch in exchange for Defendants training Plaintiffs' horses, including the subject horse Bella.

Id. at 3:22-24. Plaintiffs allege that they intended to profit from Bella by breeding her and

selling her eggs. Id. at 3:25-4:1.

Plaintiffs allege that more than two years after hiring Mr. Arballo, Plaintiff Torkington

began hearing rumors that he was using abusive training techniques on the horses he trained at

RVR. Id. at 4:4-13. However, Plaintiffs allege that the reports were unfounded, as supported by

inspections by an Animal Control Officer, an independent veterinarian, and by Ms. Torkington

herself Plaintiffs allege that no one found any signs of abuse and that "the results were

negative." Id. at 4:14.

As to the subject incident, Plaintiffs allege that on September 21, 2013, Defendants

"bitted up Bella with a shank bit and inexplicably left Bella unsupervised inside a round pen in

this contorted position." Id. at 5:16-17. Plaintiffs allege that Bella was later found injured. Id.

at 5:18-19. Plaintiff Torkington affirms that she was not present when the alleged injuries

occurred. Id. at 5:21-22. As a result of her injuries, Bella had to be humanely euthanized. Id. at

5:24-25. Plaintiff Torkington now seeks to recover damages, including vet costs and speculative

lost profits, plus attorney's fees and punitive damages. Plaintiff RVR seeks to recover economic

and "general" damages as well as attorney's fees and punitive damage claims. Mr. Arballo has

filed a motion to strike Plaintiffs' requests for attorney's fees and punitive damages, as well as

Ms. Torkington's claims for emotional distress arising from negligence concurrently with this

demurrer.

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28 WALSH MCKEAN F URCOL 0 LIP


SAN DIEGO, CALIFORNIA 92101

TELEPHONE (619) 2310485



/ / /


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III. SUMMARY OF APPLICABLE LAW

Under California law, a party is permitted to file a general demurrer to "test the legal

sufficiency of factual allegations" of an opponent's pleading. Consumer Cause, Inc. v.

Arkopharma, Inc. (2003) 106 Cal.App.4th 824, 827.) A complaint is subject to a general

demurrer if it fails to state sufficient facts to constitute a cause of action. C.C.P. § 430.10(e);

Schmier v. Supreme Ct. (2000) 78 Cal.App.4th 703, 707. A defendant may demur to a

complaint on the ground that the pleading is "uncertain" which is defined to mean that it is

"ambiguous and unintelligible." C.C.P. § 430.10(e). The requirement is that the allegations be

"sufficiently clear to apprise the defendant of the issues he is to meet" Smith v. Williams (1961)

55 Ca1.2d 617, 619 or "the nature, source, and extent" of the cause of action. Longshore v.

County of Ventura (1979) 24 Ca1.3d 14, 30.

A demurrer to a complaint may be taken to the whole complaint or to any of the causes of

action stated therein. (CCP § 430.50.) Although courts must treat as true all material facts

alleged in the challenged pleading, "contentions, deductions or conclusions of fact or law alleged

in the [pleading] are not considered in judging" the pleading's sufficiency. State v. Bank of Am.

Corp. (2005) 126 Cal.App.4th 225, 239-240 (citation omitted). In ruling on a demurrer, doubt in

the complaint may be resolved against plaintiff, and facts not alleged are presumed not to exist.

Kramer v. Intuit Inc. (2004) 121 Cal.App.4th 574, 574.

IV. PLAINTIFFS' COMPLAINT IS FATALLY UNCERTAIN AND FAILS TO

STATE A CAUSE OF ACTION FOR NEGLIGENCE PER SE BECAUSE

NEGLIGENCE PER SE IS NOT AN INDEPENDENT CAUSE OF ACTION.

Plaintiffs' second cause of action is for negligence per se based on an alleged violation of

Penal Code section 597. Under Evidence Code section 669, a plaintiff can establish a

presumption of negligence if he can prove:

(1) The defendant violated a statute, ordinance, or regulation of a public entity;

(2) The violation proximately caused death or injury to person or property;



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28 WALSH MCKEAN FU3CCLO UP


SAN DIEGO. CAL IFORNIA 92101

TELEPHONE (619) 231-9406


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(3) The death or injury resulted from an occurrence of the nature which the statute, ordinance, or regulation was designed to prevent; and

(4) The person suffering the death or the injury to his person or property was one of the class of persons for whose protection the statute, ordinance, or regulation was adopted.

However," RThe doctrine of negligence per se is not a separate cause of action." Das v.

Bank of Am., N.A. (2010) 186 Cal. App. 4th 727, 737-38 (citations omitted.) Instead,

negligence per se is an evidentiary doctrine that merely "creates an evidentiary presumption that

affects the standard of care in a cause of action for negligence." Id. Therefore, Mr. Arballo

demurs to Plaintiffs' claim for negligence per se on the grounds that they fail to state a cause of

action and the complaint is uncertain because Plaintiffs purport to bring a cause of action that

does not exist. As Plaintiffs cannot amend their complaint to bring a claim for negligence per se,

Mr. Arballo requests that the court sustain his demurrer without leave to amend.

V. PLAINTIFFS CANNOT SUPPORT A CLAIM FOR NEGLIGENCE BASED ON

PENAL CODE SECTION 597 BECAUSE PLAINTIFFS ARE NOT WITHIN THE

CLASS OF PERSONS PENAL CODE 597 IS INTENDED TO PROTECT.

As set forth above, to establish a presumption of negligence under Evidence Code section

669, the plaintiff must prove not only that the defendant violated a statute or regulation and that

the violation caused plaintiffs injury, but also that the plaintiff suffered the injury the statute was

intended to protect against and that the plaintiff is within the class of persons for whose

protection the statute or regulation was adopted. Evid. Code §669. "The first two elements are

normally questions for the trier of fact and the last two are determined by the trial court as a

matter of law." Jacobs Farm/Del Cabo, Inc. v. Western Farm Service, Inc. (2010) 190

Cal.App.4th 1502, 1526. Plaintiffs fail to state a cause of action for negligence per se because

Plaintiffs have not, and cannot, show that they are in the class of persons for whose protection

the statute was adopted. Accordingly, Mr. Arballo's demurrer should be sustained.

While no case has specifically addressed the negligence per se factors as applied to Penal

Code section 597, several courts have pointed out in dicta that the intent of section 597 is to

protect animals and to prevent cruelty to animals. See, People v. Speegle (1997) 53 Cal.App.4th



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28 WALSH MCKEAN FURCOLO LP

550 WEST C STREET BUTE 950

SAN DIEGO, CALIF ORMA 92101

TELEPHONE (619)7324486


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1405, 1418, stating "[i]n the panoply of statutes from section 596 through 599f, the Legislature

has manifested an unmistakable intent to prevent cruelty to animals"; see also, People v. Dunn

(1974) 39 Cal.App.3d 418, stating that section 597 was "intended to prohibit cruelty to animals";

People v. Superior Court (Elder) (1998) 201 Cal. App. 3d 1061, 1073, stating that an

interpretation of 597b as requiring specific intent by a spectator of animal fighting "is consistent

with, and implicit in, the Legislature's intent to prevent cruelty to animals."

Therefore, the statute is clearly intended to protect animals. Neither Ms. Torkington nor

RVR are within this class that the statute is intended to protect. Accordingly, they not only fail

to state a cause of action for negligence per se, and but Plaintiffs cannot rely on Penal Code

section 597 to set a standard of care for Defendants because they have not, and cannot, establish

that Penal Code section 597 was intended to protect them. Accordingly, the Court should sustain

Mr. Arballo's demurrer to this cause of action and further order that Plaintiff cannot establish

their claim for negligence based on any purported violation of Penal Code section 597 because

they cannot meet the requirements of Evidence Code section 669; to wit, that Penal Code section

597 is intended to protect Plaintiffs.

VI. PLAINTIFFS FAIL TO STATE A CAUSE OF ACTION FOR GROSS

NEGLIGENCE, RECKLESSNESS OR WILLFUL CONDUCT.

Plaintiffs' first cause of action for negligence is captioned as "FIRST CAUSE OF

ACTION Negligence (Including Gross Negligence, Recklessness, and Willful Misconduct)."

While gross negligence, recklessness and willful misconduct are not separate causes of action,

they still require additional pleadings beyond the basic negligence allegations of duty, breach,

causation and damages. Here, Plaintiffs simply allege that Defendants' actions "were negligent,

grossly negligent, reckless and/or intentional" without anything further.

To set forth a claim for "gross negligence" the plaintiff must allege extreme conduct on

the part of the defendant. Rosencrans v. Dover Images. Ltd. (2011) 192 Cal.App.4th 1072, 1082.

They have not done so. Similarly, Plaintiffs do not allege any facts constituting reckless

conduct." Recklessness" refers to a "subjective state of culpability greater than simple

negligence, which has been described as a 'deliberate disregard' of the 'high degree of

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28 WALSH MCKEAN FURC01.011P

550 WEST C MEET SUITE 960

SAN 0 IT GO, CALIF ORNIA 92101

TD_EPHONE (619) 232-64e6




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probability' that an injury will occur. Delaney v. Baker (1999) 20 Ca1.4th 23, 31. Indeed, unlike

negligence, recklessness "involves more than 'inadvertence, incompetence, unskillfulness, or a

failure to take precautions' but rather rises to the level of a 'conscious choice of a course of

action ... with knowledge of the serious danger to others involved in it.' " Id. at 31-32. Again,

no such allegations supPorting a claim of recklessness are made in Plaintiffs' complaint.

Finally, to plead willful misconduct, "Nile act or omission must be even more

specifically described in order to raise it to the level of willful misconduct." Berkley v. Dowds,

152 Cal. App. 4th 518, 528 (2007) (affirming trial court's ruling sustaining a demurrer to

complaint for "willful conduct" without leave to amend.) No claim of willful misconduct can be

stated without alleging the specific act or omission that caused the injury plus three additional

elements which "'raise a negligent act to the level of wilful misconduct: (1) actual or

constructive knowledge of the peril to be apprehended, (2) actual or constructive knowledge that

injury is a probable, as opposed to a possible, result of the danger, and (3) conscious failure to

act to avoid the peril.' " Id citing to Simmons v. Southern Pac. Transportation Co. (1976) 62

Cal.App.3d 341, 360. Plaintiffs have not alleged any of the three specific elements required to

plead a claim for willful misconduct. Accordingly, the complaint fails to state a cause of action

for gross negligence, recklessness and willful misconduct. Mr. Arballo therefore requests that

the Court sustain his demurrer as to these aggravated allegations of negligence without leave to

amend.

VII. PLAINTIFF TORKINGTON'S COMPLAINT IS UNCERTAIN AS TO HER

TRESPASS TO CHATTELS CLAIM BECAUSE TORICINGTON HAS ALLEGED

THE TOTAL LOSS OF HER PROPERTY.

Ms. Torkington contends that as a result of Defendants' actions, she has been completely

dispossessed of her personal property. The total dispossession of property supports a claim for

conversion. The tort of trespass to chattels is intended for "for interferences with the possession

of chattels which are not sufficiently important to be classed as conversion, and so to compel the

defendant to pay the full value of the thing with which he has interfered. Trespass to chattels

survives today, in other words, largely as a little brother of conversion." Thrifty-Tel. Inc. v.

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28 WALSH IACKEAN FURCOLOLLP


SAN DIEGO, CAL !FORMA 92101

TELEPHONE 1619) 232-846


TORICINGTON'S AND RIVER VALLEY RANCH, LLC'S COMPLAINT


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Bezenek (1996) 46 Cal. App. 4th 1559, 1566-67 citing to Prosser & Keeton on Torts (5th ed.

1984) § 14, pp. 85-86. Moreover, "[w]here the conduct complained of does not amount to a

substantial interference with possession or the right thereto, but consists of intermeddling with or

use of ... the personal property, the owner has a cause of action for trespass" to chattel, but not

for conversion. Zaslow v. ICroenert (1946) 29 Ca1.2d 541, 551.

Here, Plaintiff Torkington alleges that she has been completely dispossessed of the use of

her horse. She has sued for conversion as a result; yet also makes a claim for the lesser, and

inapplicable, cause of action for trespass. While acknowledging that plaintiffs may allege

inconsistent theories, Mr. Arballo contends that the allegation of both a trespass to chattels claim

and a conversion claim renders the complaint uncertain as to the relief requested. If Plaintiff has

been dispossessed of her property, as she contends, then she has a claim for conversion. If not,

then she has a claim for trespass. However, she does not have a claim for both.

Based on the foregoing, Defendant ARBALLO respectfully requests that the Court

sustain his demurrer as to the trespass to chattels claim without leave to amend.

VIII. PLAINTIFF TORKINGTON FAILS TO STATE A CAUSE OF ACTION FOR

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS BECAUSE SHE

CANNOT ESTABLISH THAT THE ALLEGED ACTS WERE DIRECTED

TOWARD HER OR OCCURRED IN HER PRESENCE.

In support of her claim for intentional infliction of emotional distress, Ms. Torkington

alleges that Defendants' bitting up of Bella was done "with the intention of causing Torkington to

suffer severe emotional distress or with reckless disregard of the probability" that she would

suffer such distress. (Complaint at 9:3-5.) However, these conclusory allegations cannot support

a claim for intentional infliction of emotional distress. Moreover, the facts as alleged by Ms.

Torkington evidence that she cannot prove the elements of a claim for intentional infliction of

emotional distress and such cause of action should be stricken.

To establish an intentional infliction of emotional distress claim, "Mt is not enough that

the conduct be intentional and outrageous. It must be conduct directed at the plaintiff; or occur

in the presence of a plaintiff of whom the defendant is aware." McMahon v. Craig (2009) 176

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550 WEST C STREET SURE 950

SAN DI EGO. CALIFORNIA 92101

TELEPHONE (619) 23243486




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Cal. App. 4th 1502, 1516 citing to Christensen v. Superior Court (1991) 54 Ca1.3d 868. 1 Here,

Plaintiff Torkington fails to state a claim for intentional infliction of emotional distress because

she cannot show that Defendants' actions were directed at her or, alternatively, that she was

present at the time the alleged outrageous conduct occurred.

First, Plaintiff Torkington has not, and cannot, allege that the alleged outrageous behavior

(the training techniques of Defendants) was directed at her. The training techniques were

obviously directed at her horse. This is similar to the case in McMahon, supra, where the

veterinarian defendant was alleged to have negligently provided veterinary care to plaintiffs dog

and then lied about it to cover up the malpractice. The defendant demurred to plaintiffs claim

for intentional infliction of emotional distress and the demurrer was sustained without leave to

amend. In upholding the trial court's ruling, the appellate court concluded that the acts of the vet

"do not meet the prerequisites for an intentional infliction of emotional distress claim because, as

we have explained, they were neither directed at [plaintiff] nor were they done in her presence."

Id. at 1516. Just as the vet's negligent acts in McMahon were not directed at the plaintiff in that

case, so to were the alleged acts of Defendants not directed at Ms. Torldngton.

Additionally, Plaintiffs alternate theory (reckless disregard of the probability that

plaintiff would suffer emotional distress) requires the presence of the plaintiff at the time of the

outrageous conduct. Christensen v. Superior Court, supra, 54 Ca1.3d 868 at 906. Yet, Plaintiffs

admit that on the date of the incident "Torkington left the ranch property" and that "[w]hile

Torkington was gone" Defendants removed Bella from her stable and bitted her up. (Complaint

at 5:13-14.) Ms. Torldngton further alleges that she had to "rush back to the ranch" upon hearing

that Bella was injured, further confirming that she was not present when the injurious incident

occurred. (Id. at 5:22.) Therefore, Plaintiff Torkington cannot establish a cause of action for

intentional infliction of emotional distress on this alternate theory either.

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I While not properly subject to demurrer, Mr. Arballo disputes that any conduct he engaged in was "intentional" or "outrageous" to support a claim for intentional infliction of emotional distress. "Bitting up" is a well-known technique in Western reining and a technique which Plaintiff Torkington endorsed and supported.

DEFENDANT MARK ARBALLO'S NOTICE OF DEMURRER AND DEMURRER TO PLAINTIFFS MARTHA TORKINGTON'S AND RIVER VALLEY RANCH, LLC'S COMPLAINT

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SAN DIEGO, CMFORNIA 92101

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By:

Accordingly, Mr. Arballo respectfully requests that the Court sustain his demurrer as to

Plaintiff Torkington's claim for intentional infliction of emotional distress without leave to

amend.

IX. CONCLUSION

Based on the foregoing, Defendant Arballo respectfully requests that this Court sustain •

his demurrer as to Plaintiffs' claims for negligence per se; gross negligence, recklessness and

willful misconduct; trespass to chattels; and intentional infliction of emotional distress. Plaintiffs

have failed to state a claim for each of these causes of action, or have pled uncertain claims

which are properly subject to demurrer.

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DATED: November 17, 2014 WALSH MCKEAN FURCOLO LLP 11

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13 RegfxffFurcolo, Esq. Ashley W. Christensen, Esq. Attorneys for Defendants MARK ARBALLO, an individual dba ARBALLO REINING HORSES; PATRICIA HOHL, an individual dba ARBALLO REINING HORSES

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SAN DIEGO. CALIFORNIA 92101

TELEPHONE (519)2320406


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Documents

of the Superior Court .1 7 RateMyHorsePRO Notice of... · DEFENDANT MARK ARBALLO'S NOTICE OF DEMURRER AND DEMURRER TO ... [Filed Concurrently with Notice of Motion and Motion to Strike;