NHC Ins. Services v. Millennium Corporate Solutions
In this consolidated appeal, appellant Millennium Corporate Solutions (Millennium) appeals from a money judgment following a jury verdict and from a postjudgment order awarding it a pro tanto credit as a result of a settlement by a joint tortfeasor, Sherry Lopez. Millennium contends (1) the trial court abused its discretion in denying a motion to bifurcate trial; (2) the trial court erred in conditionally granting Millennium’s motion for a new trial because the negligent interference claim was preempted by the California Uniform Trade Secrets Act, Civil Code sections 3426 to 3426.11 (CUTSA); (3) the court erred in denying Millennium’s motion for a judgment notwithstanding the verdict (JNOV) because there was insufficient evidence to support the jury’s verdict; and (4) the court erred in calculating the credit for the Lopez settlement. We conclude the trial court did not err in denying the bifurcation motion and the motion for a JNOV, but erred in conditionally granting the motion for a new trial. We further conclude the court did not err in calculating the offset credit for the Lopez settlement. Accordingly, we affirm in part, reverse in part, and remand for a recalculation of the amount of the money judgment against Millennium.
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