Alfredo Herrera Vs Hilbert Property Management, An Unknown Business Entity

Complaint

Stipulation - No Order Second Stipulation to Continue Trial and All Pre-Trial Dates and Deadlines; Filed by: Hilbert Property Management (Defendant); As to: Alfredo Herrera (Plaintiff)

Declaration DECLARATION OF ADAM A. HUTCHINSON IN SUPPORT OF HILBERT PROPERTY MANAGEMENT?S EX PARTE APPLICATION TO CONTINUE TRIAL; Filed by: Hilbert Property Management (Defendant)

Motion in Limine No. 11 of Defendant Hilbert Property Management to Exclude All Evidence of Mark Hilberts Privileged Notes; Filed by: Hilbert Property Management (Defendant)

Order Ruling; Filed by: Clerk

Amended Complaint; Filed by: Alfredo Herrera (Plaintiff); As to: Hilbert Property Management (Defendant)

Civil Case Cover Sheet; Filed by: Alfredo Herrera, an individual (Plaintiff); As to: Hilbert Property Management, an unknown business entity (Defendant)

Opposition DEFENDANT HILBERT PROPERTY MANAGEMENT?S OPPOSITION TO PLAINTIFF?S BELATED MOTION IN LIMINE #2; DECLARATION OF ADAM A. HUTCHINSON; Filed by: Hilbert Property Management (Defendant)

Notice of Case Assignment - Unlimited Civil Case; Filed by: Clerk

Answer; Filed by: Mark Hilbert (Defendant)

Proof of Service by Mail; Filed by: Alfredo Herrera (Plaintiff); As to: Hilbert Property Management (Defendant); Mark Hilbert (Defendant)

Notice of Posting of Jury Fees; Filed by: Mark Hilbert (Defendant)

Opposition PLAINTIFF?S LIMITED OPPOSITION TO DEFENDANT?S MOTION IN LIMINE #1 TO EXCLUDE EVIDENCE OF DEFENDANTS? WEALTH, ASSETS, AND FINANCIAL CONDITION; MEMORANDUM OF POINTS AND AUTHORITIES; Filed by: Alfredo Herrera (Plaintiff)

Notice of Case Management Conference; Filed by: Clerk

Answer; Filed by: Mark Hilbert (Defendant); As to: Alfredo Herrera (Plaintiff)

Motion in Limine No. 4 to Exclude Evidence it Delayed Plaintiff and Others from Seeking Workers Compensation Benefits; Filed by: Hilbert Property Management (Defendant)

Updated -- Stipulation and Order Stipulation to Bifurcate Punitive Damages at Trial: Filed By: Hilbert Property Management (Defendant); Result: Granted; Result Date:

Updated -- Stipulation and Order FOR DEFENSE MENTAL EXAMINATION OF PLAINTIFF ALFREDO HERRERA; [PROPOSED] ORDER THERON: Filed By: Hilbert Property Management (Defendant); Result: Granted; Result Date:

Certificate of Mailing for (Court Order) of ; Filed by: Clerk

Proof of Service (not Summons and Complaint); Filed by: Hilbert Property Management (Defendant); As to: Alfredo Herrera (Plaintiff)

Motion in Limine No. 2 of Defendant Hilbert Property Management to Exclude All Evidence of Other Dissimilar Claims Alleged Against HPM; Filed by: Hilbert Property Management (Defendant)

Reply iso HPM MIL No. 3 to Exclude Lay and Expert Testimony re Plaintiff's Claimed Damages for Past and Future Wages and Benefits; Filed by: Hilbert Property Management (Defendant)

Association of Attorney; Filed by: Hilbert Property Management (Defendant)

Opposition TO DEFENDANT HILDERT PROPERTY MANAGEMENTS? MOTION IN LIMINE #2 TO EXCLUDE ALL EVIDENCE OF ELIZABETH HERRERA?S CLAIMS AND OTHER DISSIMILAR CLAISM; MEMORANDUM OF POINTS AND AUTHORITIES; Filed by: Alfredo Herrera (Plaintiff)

Witness List JOINT; Filed by: Hilbert Property Management (Defendant)

Motion in Limine #1 FOR ORDER TO EXCLUDE WITNESSES AND EVIDENCE NOT IDENTIFIED IN DISCOVERY; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF DANIEL J. FRIEDMAN; Filed by: Alfredo Herrera (Plaintiff)

Objection DEFENDANT HILBERT PROPERTY MANAGEMENT?S OBJECTION TO PLAINTIFF?S NOTICE OF RULING ON THE COURT?S ORDER RE: FINAL STATUS CONFERENCE HEARING OF OCTOBER 15, 2021; Filed by: Hilbert Property Management (Defendant)

Reply iso MIL No. 10 to Exclude all Evidence of Martha Pyne's Claims and Other Dissimilar Claims Alleged Against HPM; Filed by: Hilbert Property Management (Defendant)

Motion in Limine No. 6 To Exclude Evidence Not Produced In Discovery; Filed by: Hilbert Property Management (Defendant)

Motion to Strike (not initial pleading); Filed by: Alfredo Herrera (Plaintiff)

Reply in Support of HPM's MIL No. 2 to Exclude All Evidence of Elizabeth Herrera's Claims and Other Dissimilar Claims Alleged Against HPM; Filed by: Hilbert Property Management (Defendant)

Witness List JOINT WITNESS LIST; Filed by: Alfredo Herrera (Plaintiff); Hilbert Property Management (Defendant)

Declaration DECLARATION OF GREGORY E. EISNER IN SUPPORT OF HILBERT PROPERTY MANAGEMENT?S EX PARTE APPLICATION TO CONTINUE TRIAL; Filed by: Hilbert Property Management (Defendant)

Proof of Service (not Summons and Complaint); Filed by: Hilbert Property Management (Defendant); As to: Alfredo Herrera (Plaintiff)

Exhibit List JOINT; Filed by: Alfredo Herrera (Plaintiff); Hilbert Property Management (Defendant)

Opposition TO DEFENDANT HILBERT PROPERTY MANAGEMENT?S MOTION IN LIMINE NO. 3 TO PRECLUDE LAY AND EXPERT TESTIMONY REGARDING PLAINTIFF'S CLAIMED DAMAGES FOR PAST AND FUTURE WAGES AND BENEFITS; Filed by: Alfredo Herrera (Plaintiff)

Updated -- Ex Parte Application Stipulated Ex Parte Application for an Order Continuing Trial, or Alternatively, to Shorten Time on Motion for Same: Filed By: Hilbert Property Management (Defendant); Result: Denied; Result Date:

Trial Brief; Filed by: Hilbert Property Management (Defendant)

Motion for Judgment on the Pleadings; Filed by: Hilbert Property Management (Defendant)

Motion in Limine No. 8 to Exclude Evidence of its Intent to Violate Wage and Hour Laws; Filed by: Hilbert Property Management (Defendant)

Updated -- Motion to Compel Further Responses to Hilbert's Request for Production of Documents: Filed By: Hilbert Property Management (Defendant); Result: Granted; Result Date:

Updated -- Stipulated Ex Parte Application to continue Trial and All Pre-Trial Dates and Deadlines: Filed By: Hilbert Property Management (Defendant); Result: Granted; Result Date:

Jury Instructions PROPOSED JURY INSTRUCTIONS; Filed by: Hilbert Property Management (Defendant)

Notice of Ruling; Filed by: Alfredo Herrera (Plaintiff)

Reply Reply iso MIL No. 7 to Exclude Video of Depositions taken by Plaintiff's Counsel Himself; Filed by: Hilbert Property Management (Defendant)

Jury Instructions; Filed by: Alfredo Herrera (Plaintiff); Hilbert Property Management (Defendant)

Stipulation - No Order Stipulation Regarding Motions in Limine; Filed by: Hilbert Property Management (Defendant); As to: Alfredo Herrera (Plaintiff)

Opposition DEFENDANT HILBERT PROPERTY MANAGEMENT?S OPPOSITION TO PLAINTIFF?S BELATED MOTION IN LIMINE #1; DECLARATION OF RHONDA L. NELSON; Filed by: Hilbert Property Management (Defendant)

Exhibit List PROPOSED JOINT TRIAL EXHIBIT LIST; Filed by: Hilbert Property Management (Defendant)

Reply iso MIL No. 6 to Exclude Evidence not Produced in Discovery; Filed by: Hilbert Property Management (Defendant)

Motion in Limine #4 TO EXCLUDE ANY SPECULATRIVE STATEMENTS THAT MR. HERRERA AND HIS FAMILY ENGAGED IN FRAUDULENT ACITITY; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF DANIEL J. FRIEDMAN; Filed by: Alfredo Herrera (Plaintiff)

Opposition TO DEFENDANT HILBERT PROPERTY MANAGEMENT?S MOTION IN LIMINE NO. 7 TO EXCLUDE VIDEO OF DEPOSITIONS TAKEN BY PLAINTIFF?S COUNSEL HIMSELF; Filed by: Alfredo Herrera (Plaintiff)

Amended Complaint FIRST AMENDED COMPLAINT FOR DAMAGES; Filed by: Alfredo Herrera (Plaintiff); As to: Hilbert Property Management (Defendant)

Case Management Statement; Filed by: Hilbert Property Management (Defendant)

Reply DEFENDANT HILBERT PROPERTY MANAGEMENT?S REPLY IN SUPPORT OF MOTION IN LIMINE NO. 4 TO EXCLUDE EVIDENCE IT DELAYED PLAINTIFF AND OTHERS FROM SEEKING WORKERS? COMPENSATION BENEFITS; Filed by: Hilbert Property Management (Defendant)

Opposition TO DEFENDANT HILBERT PROPERTY MANAGEMENT?S MOTION IN LIMINE NO. 11 TO EXCLUDE ALL EVIDENCE OF MARK HILBERT?S PRIVILEGED NOTES; Filed by: Alfredo Herrera (Plaintiff)

Opposition DEFENDANT HILBERT PROPERTY MANAGEMENT?S OPPOSITION TO PLAINTIFF?S BELATED MOTION IN LIMINE #5; DECLARATION OF RHONDA L. NELSON; Filed by: Hilbert Property Management (Defendant)

Motion in Limine #5 FOR ORDER PRECLUDING DEFENDANT FROM ELICITING OR INTRODUCING INADMISSIBLE EVIDENCE CONCERNING PLAINTIFFS IMMIGRATION STATUS AND REFERRING TO PLAINTIFF AS ANYTHING OTHER THAN NOT YET A UNITED STATES CITIZEN; MEMORAND; Filed by: Alfredo Herrera (Plaintiff)

Separate Statement; Filed by: Hilbert Property Management (Defendant)

Motion in Limine No. 13 to Exclude Jessica Herrera From Testifying at Trial; Declaration of Aileen Hunter in Support Thereof; Filed by: Hilbert Property Management (Defendant)

Opposition DEFENDANT HILBERT PROPERTY MANAGEMENT?S OPPOSITION TO PLAINTIFF?S BELATED MOTION IN LIMINE #4; DECLARATION OF RHONDA L. NELSON; Filed by: Hilbert Property Management (Defendant)

Proof of Service (not Summons and Complaint); Filed by: Hilbert Property Management (Defendant); As to: Alfredo Herrera (Plaintiff)

Motion to Compel Further Responses to Hilbert's Request for Production of Documents; Filed by: Hilbert Property Management (Defendant); As to: Alfredo Herrera (Plaintiff)

Declaration DECLARATION OF DANIEL J. FRIEDMAN (PLAINTIFF?S COUNSEL) IN OPPOSITION TO DEFENDANTS, HILBERT PROPERTY MANAGEMENT?S MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE; Filed by: Alfredo Herrera (Plaintiff)

Motion in Limine No. 7 of Defendant Hilbert Property Management to Exclude Video of Depositions Taken by Plaintiffs Counsel Himself; Filed by: Hilbert Property Management (Defendant)

Notice of Ruling; Filed by: Hilbert Property Management (Defendant)

Ex Parte Application DEFENDANT HILBERT PROPERTY MANAGEMENT?S EX PARTE APPLICATION FOR AN ORDER CONTINUING TRIAL, OR ALTERNATIVELY, TO SHORTEN TIME ON MOTION FOR SAME; MEMORANDUM OF POINTS AND AUTHORITIES; Filed by: Hilbert Property Management (Defendant); As to: Alfredo Herrera (Plaintiff)

Notice OF ENTRY OF ORDER FOR DEFENSE MENTAL EXAMINATION OF PLAINTIFF ALFREDO HERRERA; Filed by: Hilbert Property Management (Defendant); As to: Alfredo Herrera (Plaintiff)

Motion in Limine No. 5 of Defendant Hilbert Property Management to Exclude Evidence of Settlement Discussions; Filed by: Hilbert Property Management (Defendant)

Declaration Meet and Confer Declaration of Adam A. Hutchinson Regarding Hilbert Property Management Motions in Limine; Filed by: Hilbert Property Management (Defendant)

Motion in Limine No. 9 of Defendant Hilbert Property Management to Exclude Evidence of Settlement Discussions; Filed by: Hilbert Property Management (Defendant)

Motion in Limine No. 10 of Defendant Hilbert Property Management to Exclude All Evidence of Martha Pynes Claims and Others Against HPM; Filed by: Hilbert Property Management (Defendant)

Updated -- Motion to Compel Further Responses to Form Interrogatories and Employment Interrogatories, Set One.: Filed By: Hilbert Property Management (Defendant); Result: Granted; Result Date:

Reply iso MIL No. 11 to Exclude all Evidence of Mark Hilbert's Privileged Notes; Filed by: Hilbert Property Management (Defendant)

Motion in Limine No. 1 to Exclude Evidence of Hilbert Property Management and Mark Hilberts Wealth, Assets and Financial Condition; Filed by: Hilbert Property Management (Defendant)

Declaration in Support of Ex Parte Application; Filed by: Hilbert Property Management (Defendant)

Opposition PLAINTIFF?S OPPOSITION TO DEFENDANT HILBERT PROPETY MANAGEMENT?S MOTION TO COMPEL FURTHER RESPONSES TOREQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE; Filed by: Alfredo Herrera (Plaintiff)

Exhibit List PROPOSED JOINT TRIAL EXHIBIT LIST; Filed by: Hilbert Property Management (Defendant)

Motion in Limine No. 12 [of 12] to Bifircate Planitiff's Equitable Claims from His Legal Claims; Filed by: Hilbert Property Management (Defendant)

Motion in Limine #2 TO EXCLUDE MR. HILBERT FROM TESTIFYING AS HIS DEPOSITION WAS NEVER COMPLETED; DECLARATION OF DANIEL J. FRIEDMAN; Filed by: Alfredo Herrera (Plaintiff)

Statement of the Case JOINT SHORT STATEMENT OF CASE; Filed by: Hilbert Property Management (Defendant)

Opposition TO DEFENDANT HILDERT PROPERTY MANAGEMENTS? MOTION IN LIMINE #10 TO EXCLUDE ALL EVIDENCE OF MARTH PYNE?S CLAIMS AND OTHERS AGAINST HPM; MEMORANDUM OF POINTS AND AUTHORITIES; Filed by: Alfredo Herrera (Plaintiff)

Proof of Service (not Summons and Complaint); Filed by: Alfredo Herrera (Plaintiff)

Notice of Change of Address or Other Contact Information; Filed by: Kaveh Sam Elihu (Attorney)

Certificate of Mailing for (Court Order) of ; Filed by: Clerk

On the Amended Complaint (1st) filed by Alfredo Herrera on , entered Request for Dismissal with prejudice filed by Alfredo Herrera as to the entire action

Certificate of Mailing for [Certificate of Mailing for (Court Order) of , Minute Order (Court Order)]; Filed by: Clerk

Notice of Case Assignment - Unlimited Civil Case

Complaint

Summons - SUMMONS ON COMPLAINT

Civil Case Cover Sheet

Notice of Case Management Conference

Amended Complaint - AMENDED COMPLAINT FIRST AMENDED COMPLAINT FOR DAMAGES

Answer

Notice of Posting of Jury Fees

Case Management Statement

Notice of Posting of Jury Fees

Motion to Strike (not initial pleading)

Demurrer - with Motion to Strike (CCP 430.10)

Proof of Service by Mail

Answer

Substitution of Attorney

Minute Order - MINUTE ORDER (POST-MEDIATION STATUS CONFERENCE)

Notice of Ruling

Minute Order - MINUTE ORDER (COURT ORDER)

Certificate of Mailing for - CERTIFICATE OF MAILING FOR (COURT ORDER) OF 10/30/2020

Minute Order - MINUTE ORDER (POST-MEDIATION STATUS CONFERENCE)

Stipulation and Order - STIPULATION AND ORDER STIPULATION TO CONTINUE TRIAL AND ALL PRE-TRIAL DATES AND DEADLINES

Ex Parte Application - EX PARTE APPLICATION STIPULATED EX PARTE APPLICATION TO CONTINUE TRIAL AND ALL PRE-TRIAL DATES AND DEADLINES

Minute Order - MINUTE ORDER (EX PARTE APPLICATION OF DEFENDANT, HILBERT PROPERTY MANAGEMEN...)

Motion to Compel - MOTION TO COMPEL FURTHER RESPONSES TO HILBERT'S FORM INTERROGATORIES AND EMPLOYMENT INTERROGATORIES, SET ONE

Separate Statement

Motion to Compel - MOTION TO COMPEL FURTHER RESPONSES TO HILBERT'S REQUEST FOR PRODUCTION OF DOCUMENTS

Declaration - DECLARATION DECLARATION OF ADAM A. HUTCHINSON IN SUPPORT OF HILBERT PROPERTY MANAGEMENT’S EX PARTE APPLICATION TO CONTINUE TRIAL

Declaration - DECLARATION DECLARATION OF GREGORY E. EISNER IN SUPPORT OF HILBERT PROPERTY MANAGEMENT’S EX PARTE APPLICATION TO CONTINUE TRIAL

Proof of Service (not Summons and Complaint)

Declaration in Support of Ex Parte Application

Ex Parte Application - EX PARTE APPLICATION STIPULATED EX PARTE APPLICATION FOR AN ORDER CONTINUING TRIAL, OR ALTERNATIVELY, TO SHORTEN TIME ON MOTION FOR SAME

Minute Order - MINUTE ORDER (EX PARTE APPLICATION OF DEFENDANT, HILBERT PROPERTY MANAGEMEN...)

Informal Discovery Conference

Minute Order - MINUTE ORDER (INFORMAL DISCOVERY CONFERENCE (IDC))

Stipulation and Order - STIPULATION AND ORDER FOR DEFENSE MENTAL EXAMINATION OF PLAINTIFF ALFREDO HERRERA; [PROPOSED] ORDER THERON

Notice - NOTICE OF ENTRY OF ORDER FOR DEFENSE MENTAL EXAMINATION OF PLAINTIFF ALFREDO HERRERA

Certificate of Mailing for - CERTIFICATE OF MAILING FOR (COURT ORDER) OF 07/12/2021

Minute Order - MINUTE ORDER (COURT ORDER)

Declaration - DECLARATION DECLARATION OF DANIEL J. FRIEDMAN (PLAINTIFF’S COUNSEL) IN OPPOSITION TO DEFENDANTS, HILBERT PROPERTY MANAGEMENT’S MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES,

Opposition - OPPOSITION PLAINTIFF’S OPPOSITION TO DEFENDANT HILBERT PROPETY MANAGEMENT’S MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES, SET ONE

Declaration - DECLARATION DECLARATION OF DANIEL J. FRIEDMAN (PLAINTIFF’S COUNSEL) IN OPPOSITION TO DEFENDANTS, HILBERT PROPERTY MANAGEMENT’S MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTIO

Reply - REPLY IN SUPPORT OF MOTION TO COMPEL

Minute Order - MINUTE ORDER (HEARING ON MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR ...)

Order - ORDER RULING

Proof of Service (not Summons and Complaint)

Motion in Limine - MOTION IN LIMINE NO. 7 OF DEFENDANT HILBERT PROPERTY MANAGEMENT TO EXCLUDE VIDEO OF DEPOSITIONS TAKEN BY PLAINTIFFS COUNSEL HIMSELF

Motion in Limine - MOTION IN LIMINE NO. 2 OF DEFENDANT HILBERT PROPERTY MANAGEMENT TO EXCLUDE ALL EVIDENCE OF OTHER DISSIMILAR CLAIMS ALLEGED AGAINST HPM

Declaration - DECLARATION MEET AND CONFER DECLARATION OF ADAM A. HUTCHINSON REGARDING HILBERT PROPERTY MANAGEMENT MOTIONS IN LIMINE

Motion in Limine - MOTION IN LIMINE NO. 11 OF DEFENDANT HILBERT PROPERTY MANAGEMENT TO EXCLUDE ALL EVIDENCE OF MARK HILBERTS PRIVILEGED NOTES

Motion in Limine - MOTION IN LIMINE NO. 8 TO EXCLUDE EVIDENCE OF ITS INTENT TO VIOLATE WAGE AND HOUR LAWS

Motion in Limine - MOTION IN LIMINE NO. 9 OF DEFENDANT HILBERT PROPERTY MANAGEMENT TO EXCLUDE EVIDENCE OF SETTLEMENT DISCUSSIONS

Motion in Limine - MOTION IN LIMINE NO. 4 TO EXCLUDE EVIDENCE IT DELAYED PLAINTIFF AND OTHERS FROM SEEKING WORKERS COMPENSATION BENEFITS

Motion in Limine - MOTION IN LIMINE NO. 5 OF DEFENDANT HILBERT PROPERTY MANAGEMENT TO EXCLUDE EVIDENCE OF SETTLEMENT DISCUSSIONS

Motion in Limine - MOTION IN LIMINE NO. 10 OF DEFENDANT HILBERT PROPERTY MANAGEMENT TO EXCLUDE ALL EVIDENCE OF MARTHA PYNES CLAIMS AND OTHERS AGAINST HPM

Motion in Limine - MOTION IN LIMINE NO. 3 TO EXCLUDE LAY AND EXPERT TESTIMONY REGARDING PLAINTIFFS CLAIMED DAMAGES FOR PAST AND FUTURE WAGES AND BENEFITS

Minute Order - MINUTE ORDER (COURT ORDER)

Certificate of Mailing for - CERTIFICATE OF MAILING FOR (COURT ORDER) OF 09/27/2021

Opposition - OPPOSITION TO DEFENDANT HILBERT PROPERTY MANAGEMENT’S MOTION IN LIMINE NO. 3 TO PRECLUDE LAY AND EXPERT TESTIMONY REGARDING PLAINTIFF'S CLAIMED DAMAGES FOR PAST AND FUTURE WAGES AND BENEF

Opposition - OPPOSITION PLAINTIFF’S LIMITED OPPOSITION TO DEFENDANT’S MOTION IN LIMINE #1 TO EXCLUDE EVIDENCE OF DEFENDANTS’ WEALTH, ASSETS, AND FINANCIAL CONDITION; MEMORANDUM OF POINTS AND AUTHORITI

Opposition - OPPOSITION TO DEFENDANT’S MOTION IN LIMINE NO. 6 TO EXCLUDE EVIDENCE PLAINTIFF FAILED OR REFUSED TO PRODUCE DURING THE COURSE OF DISCOVERY

Opposition - OPPOSITION TO DEFENDANT HILBERT PROPERTY MANAGEMENT’S MOTION IN LIMINE NO. 11 TO EXCLUDE ALL EVIDENCE OF MARK HILBERT’S PRIVILEGED NOTES

Opposition - OPPOSITION TO DEFENDANT’S MOTION IN LIMINE #4 TO EXCLUDE EVIDENCE IT DELAYED PLAINTIFF AND OTHERS FROM SEEKING WORKERS’ COMPENSATION BENEFITS

Opposition - OPPOSITION TO DEFENDANT HILBERT PROPERTY MANAGEMENT’S MOTION IN LIMINE NO. 7 TO EXCLUDE VIDEO OF DEPOSITIONS TAKEN BY PLAINTIFF’S COUNSEL HIMSELF

Opposition - OPPOSITION TO DEFENDANT HILDERT PROPERTY MANAGEMENTS’ MOTION IN LIMINE #2 TO EXCLUDE ALL EVIDENCE OF ELIZABETH HERRERA’S CLAIMS AND OTHER DISSIMILAR CLAISM; MEMORANDUM OF POINTS AND AUTHO

Opposition - OPPOSITION TO DEFENDANT HILDERT PROPERTY MANAGEMENTS’ MOTION IN LIMINE #10 TO EXCLUDE ALL EVIDENCE OF MARTH PYNE’S CLAIMS AND OTHERS AGAINST HPM; MEMORANDUM OF POINTS AND AUTHORITIES

Motion in Limine - MOTION IN LIMINE #1 FOR ORDER TO EXCLUDE WITNESSES AND EVIDENCE NOT IDENTIFIED IN DISCOVERY; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF DANIEL J. FRIEDMAN

Proof of Service (not Summons and Complaint)

Motion in Limine - MOTION IN LIMINE #2 TO EXCLUDE MR. HILBERT FROM TESTIFYING AS HIS DEPOSITION WAS NEVER COMPLETED; DECLARATION OF DANIEL J. FRIEDMAN

Motion in Limine - MOTION IN LIMINE #4 TO EXCLUDE ANY SPECULATRIVE STATEMENTS THAT MR. HERRERA AND HIS FAMILY ENGAGED IN FRAUDULENT ACITITY; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF DANIEL

Reply - REPLY IN SUPPORT OF HPM'S MIL NO. 2 TO EXCLUDE ALL EVIDENCE OF ELIZABETH HERRERA'S CLAIMS AND OTHER DISSIMILAR CLAIMS ALLEGED AGAINST HPM

Trial Brief

Reply - REPLY DEFENDANT HILBERT PROPERTY MANAGEMENT’S REPLY IN SUPPORT OF MOTION IN LIMINE NO. 4 TO EXCLUDE EVIDENCE IT DELAYED PLAINTIFF AND OTHERS FROM SEEKING WORKERS’ COMPENSATION BENEFITS

Reply - REPLY REPLY ISO MIL NO. 7 TO EXCLUDE VIDEO OF DEPOSITIONS TAKEN BY PLAINTIFF'S COUNSEL HIMSELF

Reply - REPLY ISO MIL NO. 10 TO EXCLUDE ALL EVIDENCE OF MARTHA PYNE'S CLAIMS AND OTHER DISSIMILAR CLAIMS ALLEGED AGAINST HPM

Reply - REPLY ISO MIL NO. 11 TO EXCLUDE ALL EVIDENCE OF MARK HILBERT'S PRIVILEGED NOTES

Reply - REPLY ISO HPM MIL NO. 3 TO EXCLUDE LAY AND EXPERT TESTIMONY RE PLAINTIFF'S CLAIMED DAMAGES FOR PAST AND FUTURE WAGES AND BENEFITS

Reply - REPLY ISO MIL NO. 6 TO EXCLUDE EVIDENCE NOT PRODUCED IN DISCOVERY

Exhibit List - EXHIBIT LIST PROPOSED JOINT TRIAL EXHIBIT LIST

Opposition - OPPOSITION DEFENDANT HILBERT PROPERTY MANAGEMENT’S OPPOSITION TO PLAINTIFF’S BELATED MOTION IN LIMINE #2; DECLARATION OF ADAM A. HUTCHINSON

Opposition - OPPOSITION DEFENDANT HILBERT PROPERTY MANAGEMENT’S OPPOSITION TO PLAINTIFF’S BELATED MOTION IN LIMINE #5; DECLARATION OF RHONDA L. NELSON

Opposition - OPPOSITION DEFENDANT HILBERT PROPERTY MANAGEMENT’S OPPOSITION TO PLAINTIFF’S BELATED MOTION IN LIMINE #1; DECLARATION OF RHONDA L. NELSON

Opposition - OPPOSITION DEFENDANT HILBERT PROPERTY MANAGEMENT’S OPPOSITION TO PLAINTIFF’S BELATED MOTION IN LIMINE #4; DECLARATION OF RHONDA L. NELSON

Motion in Limine - MOTION IN LIMINE NO. 12 [OF 12] TO BIFIRCATE PLANITIFF'S EQUITABLE CLAIMS FROM HIS LEGAL CLAIMS

Minute Order - MINUTE ORDER (FINAL STATUS CONFERENCE)

Witness List - WITNESS LIST JOINT WITNESS LIST

Association of Attorney

Exhibit List - EXHIBIT LIST JOINT

Minute Order - MINUTE ORDER (FINAL STATUS CONFERENCE)

Notice of Ruling

Objection - OBJECTION DEFENDANT HILBERT PROPERTY MANAGEMENT’S OBJECTION TO PLAINTIFF’S NOTICE OF RULING ON THE COURT’S ORDER RE: FINAL STATUS CONFERENCE HEARING OF OCTOBER 15, 2021

Motion for Judgment on the Pleadings

Jury Instructions - JURY INSTRUCTIONS PROPOSED JURY INSTRUCTIONS

Statement of the Case - STATEMENT OF THE CASE JOINT SHORT STATEMENT OF CASE

Exhibit List - EXHIBIT LIST PROPOSED JOINT TRIAL EXHIBIT LIST

Stipulation - No Order - STIPULATION - NO ORDER STIPULATION REGARDING MOTIONS IN LIMINE

Motion in Limine - MOTION IN LIMINE NO. 13 TO EXCLUDE JESSICA HERRERA FROM TESTIFYING AT TRIAL; DECLARATION OF AILEEN HUNTER IN SUPPORT THEREOF

Witness List - WITNESS LIST JOINT

Minute Order - MINUTE ORDER (FINAL STATUS CONFERENCE)

Notice of Change of Address or Other Contact Information

Notice of Settlement

Minute Order - MINUTE ORDER (COURT ORDER)

Certificate of Mailing for - CERTIFICATE OF MAILING FOR (COURT ORDER) OF 01/19/2022

Certificate of Mailing for - CERTIFICATE OF MAILING FOR [CERTIFICATE OF MAILING FOR (COURT ORDER) OF 01/19/2022, MINUTE ORDER (COURT ORDER)]

Minute Order - MINUTE ORDER (ORDER TO SHOW CAUSE REGARDING DISMISSAL AFTER SETTLEMENT)

Request for Dismissal

Motion to Compel (Further Responses to Hilbert's Request for Production of Documents)

Declaration (DECLARATION OF GREGORY E. EISNER IN SUPPORT OF HILBERT PROPERTY MANAGEMENT?S EX PARTE APPLICATION TO CONTINUE TRIAL)

Declaration (DECLARATION OF ADAM A. HUTCHINSON IN SUPPORT OF HILBERT PROPERTY MANAGEMENT?S EX PARTE APPLICATION TO CONTINUE TRIAL)

Minute Order ( (Court Order))

Opposition TO DEFENDANT?S MOTION IN LIMINE NO. 6 TO EXCLUDE EVIDENCE PLAINTIFF FAILED OR REFUSED TO PRODUCE DURING THE COURSE OF DISCOVERY; Filed by: Alfredo Herrera (Plaintiff)

Notice of Posting of Jury Fees; Filed by: Alfredo Herrera (Plaintiff)

Declaration DECLARATION OF DANIEL J. FRIEDMAN (PLAINTIFF?S COUNSEL) IN OPPOSITION TO DEFENDANTS, HILBERT PROPERTY MANAGEMENT?S MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES, SET ONE; Filed by: Alfredo Herrera (Plaintiff)

Substitution of Attorney; Filed by: Mark Hilbert (Defendant)

Certificate of Mailing for (Court Order) of ; Filed by: Clerk

Motion in Limine No. 3 to Exclude Lay and Expert Testimony Regarding Plaintiffs Claimed Damages for Past and Future Wages and Benefits; Filed by: Hilbert Property Management (Defendant)

Case Management Statement; Filed by: Alfredo Herrera (Plaintiff)

Opposition TO DEFENDANT?S MOTION IN LIMINE #4 TO EXCLUDE EVIDENCE IT DELAYED PLAINTIFF AND OTHERS FROM SEEKING WORKERS? COMPENSATION BENEFITS; Filed by: Alfredo Herrera (Plaintiff)

Complaint; Filed by: Alfredo Herrera, an individual (Plaintiff); As to: Hilbert Property Management, an unknown business entity (Defendant)

Certificate of Mailing for (Court Order) of ; Filed by: Clerk

Reply In Support Of Motion To Compel; Filed by: Hilbert Property Management (Defendant)

Demurrer - with Motion to Strike (CCP 430.10); Filed by: Alfredo Herrera (Plaintiff)

Motion to Compel Further Responses to Hilbert's Form Interrogatories and Employment Interrogatories, Set One; Filed by: Hilbert Property Management (Defendant); As to: Alfredo Herrera (Plaintiff)

Summons on Complaint; Issued and Filed by: Alfredo Herrera, an individual (Plaintiff); As to: Hilbert Property Management, an unknown business entity (Defendant)

Ex Parte Application Stipulated Ex Parte Application for an Order Continuing Trial, or Alternatively, to Shorten Time on Motion for Same; Filed by: Hilbert Property Management (Defendant); As to: Alfredo Herrera (Plaintiff)

Opposition PLAINTIFF?S OPPOSITION TO DEFENDANT HILBERT PROPETY MANAGEMENT?S MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES, SET ONE; Filed by: Alfredo Herrera (Plaintiff)

Proof of Service (not Summons and Complaint)

Ex Parte Application (DEFENDANT HILBERT PROPERTY MANAGEMENT?S EX PARTE APPLICATION FOR AN ORDER CONTINUING TRIAL, OR ALTERNATIVELY, TO SHORTEN TIME ON MOTION FOR SAME; MEMORANDUM OF POINTS AND AUTHORITIES)

Stipulation and Order (Stipulation to Bifurcate Punitive Damages at Trial)

Proof of Service (not Summons and Complaint)

Ex Parte Application (Stipulated Ex Parte Application for an Order Continuing Trial, or Alternatively, to Shorten Time on Motion for Same)

Minute Order ( (Ex Parte Application of Defendant, Hilbert Property Managemen...))

Informal Discovery Conference

Minute Order ( (Informal Discovery Conference (IDC)))

Stipulation - No Order (Second Stipulation to Continue Trial and All Pre-Trial Dates and Deadlines)

Certificate of Mailing for ((Court Order) of 07/12/2021)

Stipulation and Order (FOR DEFENSE MENTAL EXAMINATION OF PLAINTIFF ALFREDO HERRERA; [PROPOSED] ORDER THERON)

Notice (OF ENTRY OF ORDER FOR DEFENSE MENTAL EXAMINATION OF PLAINTIFF ALFREDO HERRERA)

Minute Order ( (Court Order))

Opposition (PLAINTIFF?S OPPOSITION TO DEFENDANT HILBERT PROPETY MANAGEMENT?S MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES, SET ONE)

Declaration (DECLARATION OF DANIEL J. FRIEDMAN (PLAINTIFF?S COUNSEL) IN OPPOSITION TO DEFENDANTS, HILBERT PROPERTY MANAGEMENT?S MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES, SET ONE)

Opposition (PLAINTIFF?S OPPOSITION TO DEFENDANT HILBERT PROPETY MANAGEMENT?S MOTION TO COMPEL FURTHER RESPONSES TOREQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE)

Order (Ruling)

Declaration (DECLARATION OF DANIEL J. FRIEDMAN (PLAINTIFF?S COUNSEL) IN OPPOSITION TO DEFENDANTS, HILBERT PROPERTY MANAGEMENT?S MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE)

Minute Order ( (Hearing on Motion to Compel Further Responses to Request for ...))

Motion in Limine (No. 8 to Exclude Evidence of its Intent to Violate Wage and Hour Laws)

Motion in Limine (No. 11 of Defendant Hilbert Property Management to Exclude All Evidence of Mark Hilberts Privileged Notes)

Declaration (Meet and Confer Declaration of Adam A. Hutchinson Regarding Hilbert Property Management Motions in Limine)

Motion in Limine (No. 7 of Defendant Hilbert Property Management to Exclude Video of Depositions Taken by Plaintiffs Counsel Himself)

Motion in Limine (No. 10 of Defendant Hilbert Property Management to Exclude All Evidence of Martha Pynes Claims and Others Against HPM)

Motion in Limine (No. 9 of Defendant Hilbert Property Management to Exclude Evidence of Settlement Discussions)

Proof of Service (not Summons and Complaint)

Motion in Limine (No. 2 of Defendant Hilbert Property Management to Exclude All Evidence of Other Dissimilar Claims Alleged Against HPM)

Motion in Limine (No. 3 to Exclude Lay and Expert Testimony Regarding Plaintiffs Claimed Damages for Past and Future Wages and Benefits)

Motion in Limine (No. 6 To Exclude Evidence Not Produced In Discovery)

Motion in Limine (No. 1 to Exclude Evidence of Hilbert Property Management and Mark Hilberts Wealth, Assets and Financial Condition)

Motion in Limine (No. 5 of Defendant Hilbert Property Management to Exclude Evidence of Settlement Discussions)

Motion in Limine (No. 4 to Exclude Evidence it Delayed Plaintiff and Others from Seeking Workers Compensation Benefits)

Opposition (TO DEFENDANT HILDERT PROPERTY MANAGEMENTS? MOTION IN LIMINE #10 TO EXCLUDE ALL EVIDENCE OF MARTH PYNE?S CLAIMS AND OTHERS AGAINST HPM; MEMORANDUM OF POINTS AND AUTHORITIES)

Minute Order ( (Court Order))

Opposition (TO DEFENDANT HILDERT PROPERTY MANAGEMENTS? MOTION IN LIMINE #2 TO EXCLUDE ALL EVIDENCE OF ELIZABETH HERRERA?S CLAIMS AND OTHER DISSIMILAR CLAISM; MEMORANDUM OF POINTS AND AUTHORITIES)

Opposition (TO DEFENDANT HILBERT PROPERTY MANAGEMENT?S MOTION IN LIMINE NO. 11 TO EXCLUDE ALL EVIDENCE OF MARK HILBERT?S PRIVILEGED NOTES)

Certificate of Mailing for ((Court Order) of 09/27/2021)

Opposition (PLAINTIFF?S LIMITED OPPOSITION TO DEFENDANT?S MOTION IN LIMINE #1 TO EXCLUDE EVIDENCE OF DEFENDANTS? WEALTH, ASSETS, AND FINANCIAL CONDITION; MEMORANDUM OF POINTS AND AUTHORITIES)

Opposition (TO DEFENDANT HILBERT PROPERTY MANAGEMENT?S MOTION IN LIMINE NO. 7 TO EXCLUDE VIDEO OF DEPOSITIONS TAKEN BY PLAINTIFF?S COUNSEL HIMSELF)

Opposition (TO DEFENDANT?S MOTION IN LIMINE #4 TO EXCLUDE EVIDENCE IT DELAYED PLAINTIFF AND OTHERS FROM SEEKING WORKERS? COMPENSATION BENEFITS)

Opposition (TO DEFENDANT?S MOTION IN LIMINE NO. 6 TO EXCLUDE EVIDENCE PLAINTIFF FAILED OR REFUSED TO PRODUCE DURING THE COURSE OF DISCOVERY)

Motion in Limine (#2 TO EXCLUDE MR. HILBERT FROM TESTIFYING AS HIS DEPOSITION WAS NEVER COMPLETED; DECLARATION OF DANIEL J. FRIEDMAN)

Opposition (TO DEFENDANT HILBERT PROPERTY MANAGEMENT?S MOTION IN LIMINE NO. 3 TO PRECLUDE LAY AND EXPERT TESTIMONY REGARDING PLAINTIFF'S CLAIMED DAMAGES FOR PAST AND FUTURE WAGES AND BENEFITS)

Reply (iso MIL No. 11 to Exclude all Evidence of Mark Hilbert's Privileged Notes)

Motion in Limine (#4 TO EXCLUDE ANY SPECULATRIVE STATEMENTS THAT MR. HERRERA AND HIS FAMILY ENGAGED IN FRAUDULENT ACITITY; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF DANIEL J. FRIEDMAN)

Reply (iso HPM MIL No. 3 to Exclude Lay and Expert Testimony re Plaintiff's Claimed Damages for Past and Future Wages and Benefits)

Motion in Limine (#5 FOR ORDER PRECLUDING DEFENDANT FROM ELICITING OR INTRODUCING INADMISSIBLE EVIDENCE CONCERNING PLAINTIFFS IMMIGRATION STATUS AND REFERRING TO PLAINTIFF AS ANYTHING OTHER THAN NOT YET A UNITED STATES CITIZEN; MEMORAND)

Reply (in Support of HPM's MIL No. 2 to Exclude All Evidence of Elizabeth Herrera's Claims and Other Dissimilar Claims Alleged Against HPM)

Motion in Limine (#1 FOR ORDER TO EXCLUDE WITNESSES AND EVIDENCE NOT IDENTIFIED IN DISCOVERY; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF DANIEL J. FRIEDMAN)

Reply (iso MIL No. 6 to Exclude Evidence not Produced in Discovery)

Notice of Ruling

Witness List (JOINT WITNESS LIST)

Jury Instructions

Association of Attorney

Reply (Reply iso MIL No. 7 to Exclude Video of Depositions taken by Plaintiff's Counsel Himself)

Objection (DEFENDANT HILBERT PROPERTY MANAGEMENT?S OBJECTION TO PLAINTIFF?S NOTICE OF RULING ON THE COURT?S ORDER RE: FINAL STATUS CONFERENCE HEARING OF OCTOBER 15, 2021)

Witness List (JOINT)

Exhibit List (PROPOSED JOINT TRIAL EXHIBIT LIST)

Notice of Change of Address or Other Contact Information

Minute Order ( (Final Status Conference))

Stipulation - No Order (Stipulation Regarding Motions in Limine)

Opposition (DEFENDANT HILBERT PROPERTY MANAGEMENT?S OPPOSITION TO PLAINTIFF?S BELATED MOTION IN LIMINE #5; DECLARATION OF RHONDA L. NELSON)

Opposition (DEFENDANT HILBERT PROPERTY MANAGEMENT?S OPPOSITION TO PLAINTIFF?S BELATED MOTION IN LIMINE #4; DECLARATION OF RHONDA L. NELSON)

Trial Brief

Reply (iso MIL No. 10 to Exclude all Evidence of Martha Pyne's Claims and Other Dissimilar Claims Alleged Against HPM)

Opposition (DEFENDANT HILBERT PROPERTY MANAGEMENT?S OPPOSITION TO PLAINTIFF?S BELATED MOTION IN LIMINE #1; DECLARATION OF RHONDA L. NELSON)

Minute Order ( (Final Status Conference))

Exhibit List (PROPOSED JOINT TRIAL EXHIBIT LIST)

Statement of the Case (JOINT SHORT STATEMENT OF CASE)

Minute Order ( (Final Status Conference))

Exhibit List (JOINT)

Motion in Limine (No. 13 to Exclude Jessica Herrera From Testifying at Trial; Declaration of Aileen Hunter in Support Thereof)

Motion for Judgment on the Pleadings

Opposition (DEFENDANT HILBERT PROPERTY MANAGEMENT?S OPPOSITION TO PLAINTIFF?S BELATED MOTION IN LIMINE #2; DECLARATION OF ADAM A. HUTCHINSON)

Reply (DEFENDANT HILBERT PROPERTY MANAGEMENT?S REPLY IN SUPPORT OF MOTION IN LIMINE NO. 4 TO EXCLUDE EVIDENCE IT DELAYED PLAINTIFF AND OTHERS FROM SEEKING WORKERS? COMPENSATION BENEFITS)

Motion in Limine (No. 12 [of 12] to Bifircate Planitiff's Equitable Claims from His Legal Claims)

Notice of Settlement

Certificate of Mailing for ((Court Order) of 01/19/2022)

Minute Order ( (Court Order))

Certificate of Mailing for ([Certificate of Mailing for (Court Order) of 01/19/2022, Minute Order (Court Order)])

Jury Instructions (PROPOSED JURY INSTRUCTIONS)

Separate Statement

Declaration in Support of Ex Parte Application

Reply (In Support Of Motion To Compel)

Proof of Service (not Summons and Complaint)

Answer

Notice of Posting of Jury Fees

Certificate of Mailing for ((Court Order) of 10/30/2020)

Notice of Case Assignment - Unlimited Civil Case

Minute Order ( (Post-Mediation Status Conference))

Minute Order ( (Ex Parte Application of Defendant, Hilbert Property Managemen...))

Substitution of Attorney

Notice of Case Management Conference

Notice of Posting of Jury Fees

Answer

Notice of Ruling

Stipulation and Order (STIPULATION TO CONTINUE TRIAL AND ALL PRE-TRIAL DATES AND DEADLINES)

Minute Order ( (Court Order))

Motion to Compel Further Responses to Form Interrogatories and Employment Interrogatories, Set One.

Minute Order ( (Case Management Conference))

Case Management Statement

Motion to Strike (not initial pleading)

Minute Order ( (Post-Mediation Status Conference))

Case Management Statement

Stipulated Ex Parte Application to continue Trial and All Pre-Trial Dates and Deadlines

Summons (on Complaint)

Civil Case Cover Sheet

Demurrer - with Motion to Strike (CCP 430.10)

Motion to Compel (Further Responses to Hilbert's Form Interrogatories and Employment Interrogatories, Set One)

Proof of Service by Mail

Ex Parte Application (STIPULATED EX PARTE APPLICATION TO CONTINUE TRIAL AND ALL PRE-TRIAL DATES AND DEADLINES)

Amended Complaint

Minute Order - MINUTE ORDER (COURT ORDER)

Stipulation and Order - STIPULATION AND ORDER STIPULATION TO BIFURCATE PUNITIVE DAMAGES AT TRIAL

Ex Parte Application - EX PARTE APPLICATION DEFENDANT HILBERT PROPERTY MANAGEMENT’S EX PARTE APPLICATION FOR AN ORDER CONTINUING TRIAL, OR ALTERNATIVELY, TO SHORTEN TIME ON MOTION FOR SAME; MEMORANDUM

Stipulation - No Order - STIPULATION - NO ORDER SECOND STIPULATION TO CONTINUE TRIAL AND ALL PRE-TRIAL DATES AND DEADLINES

Proof of Service (not Summons and Complaint)

Amended Complaint (1st)