Tanya Hijazi Vs Food Forward Inc Et Al

Proof of Service Personal Service -

NOTICE OF MOTION AND MOTION FOR ORDER TO COMPEL PLAINTIFF TO PROVIDE FURTHER RESPONSES TO DEMAND FOR IDENTIFICATION AND INSPECTION OF DOCUMENTS; ETC.

NOTICE OF MOTION AND MOTION FOR ORDER TO COMPEL PLAINTIFF TO PROVIDE FURTHER RESPONSES TO JUDICIAL COUNCIL FORM INTERROGATORIES; ETC.

NOTICE OF MOTION AND MOTION FOR ORDER TO COMPEL PLAINTIFF TO PROVIDE FURTHER RESPONSES TO SPECIAL INTERROGATORIES; ETC.

[ORDER] AND STIPULATION TO CONTINUE TRIAL, FSC [AND RELATED MOTION/DISCOVERY DATES] PERSONAL INJURY COURTS ONLY (CENTRAL DISTRICT)

ORDER AND STIPULATION TO CONTINUE TRIAL, FSC [AND RELATED MOTION/DISCOVERY DATES] PERSONAL INJURY COURTS ONLY (CENTRAL DISTRICT)

DECLARATION OF AMIR ZAMBRANO IN SUPPORT OF DEFENDANT FOOD FORWARD, INC.'S MOTION FOR SUMMARY JUDGMENT

SEPARATE STATEMENT OF UNDISPUTED MATERIAL FACTS IN SUPPORT OF DEFENDANT FOOD FORWARD, INC.'S MOTION FOR SUMMARY JUDGMENT

DECLARATION OF WEYD-ANNE MILLER IN SUPPORT OF DEFENDANT FOOD FORWARD, INC.'S MOTION FOR SUMMARY JUDGMENT

VOLUME OF EVIDENCE IN SUPPORT OF DEFENDANT FOOD FORWARD, INC.'S MOTION FOR SUMMARY JUDGMENT

REQUEST FOR COURT TO TAKE JUDICIAL NOTICE IN SUPPORT OF DEFENDANTS FOOD FORWARD'S MOTION FOR SUMMARY JUDGMENT

NOTICE OF MOTION AND MOTION FOR SUMMARY JUDGMENT OF DEFENDANT FOOD FORWARD, INC., OR IN THE ALTERNATIVE FOR SUMMARY ADJUDICATION OF ISSUES; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF

DECLARATION - OF PHILLIP L. ROSESCU IN SUPPORT OF PLAINTIFF?S OPPOSITION TO DEFENDANT FOOD FORWARD INC.?S MOTION FOR SUMMARY JUDGMENT

PLAINTIFF TANYA HIJAZIS OBJECTIONS TO DEFENDANTS FOOD FORWARD INC.S EVIDENCE IN SUPPORT OF ITS MOTIONS FOR SUMMARY JUDGMENT

PLAINTIFF TANYA HIJAZI'S OPPOSITION TO DEFENDANT FOOD FORWARD, INC.?S MOTION FOR SUMMARY JUDGMENT

MOTION IN LIMINE NO. 1 MOTION IN LIMINE TO EXCLUDE ANY AND ALL REFERENCES TO THE WORKERS' COMPENSATION LIEN ASSERTED BY CNA FOR PLAINTIFF'S MEDICAL TREATMENT RELATED TO THE SUBJECT INCIDENT, ETC

DEFENDANT'S MOTION IN LIMINE NO. 3 PRECLUDE ANY MENTION OF SUBSEQUENT REMEDIAL MEASURES OF FOOD FORWARD AND EMPLOYEES; [PROPOSED] ORDER

DEFENDANT'S MOTION IN LIMINE NO. 2 NO ACTUAL OR POTENTIAL DOLLAR AMOUNT OF DAMAGES IN THIS OR ANY OTHER HYPOTHETICAL CASE BE MENTIONED TO THE JURY DURING VOIR DIRE; [PROPOSED] ORDER

DEFENDANT'S MOTION IN LIMINE NO. 1 PRECLUDE PLAINTIFF AND ALL WITNESSES CALLED ON PLAINTIFF'S BEHALF NOT ATTEMPT TO CONVEY TO THE JURY THE DIAGNOSIS, CAUSE, OR PROGNOSIS OF PLAINTIFF'S CONDITION AND R

Opposition - Defendants opposition to plaintiffs motion in limine no.1

Motion in Limine - Motion in Limine #2

Motion in Limine - NO. 3

Motion in Limine -

Motion in Limine -

Motion in Limine - DEFENDANT'S AMENDED MOTION IN LIMINE NO.3 TO PRECLUDE ANY MENTIONS OF SUBSEQUENT REMEDIAL MEASURES OF FOOD FORWARD AND EMPLOYEES

Reply - Reply DEFENDANTS REPLY TO PLAINTIFF'S OPPOSITION RTO DEFENDANTS MOTION IN LIMINE NO. 2

Opposition - Plaintiff's Opposition to Defendant's Motion In Limine No. 9 to Limit Testimony of Plaintiff's Expert Witnesses to Those Opinions in Their Deposition

Opposition - Plaintiff's Opposition to Defendant's Motion In Limine No. 7 to Exclude Evidence Not Disclosed In Discovery

Opposition - Plaintiff's Opposition to Defendant's Amended Motion In Limine No.3 to Preclude Any Mention of Subsequent Remedial Measures of Defendant and Defendant's Employees

Opposition - Plaintiff's Opposition to Defendant's Motion In Limine No . 8 to Exclude Evidence of Medical Bills Except as to Those Amounts Paid

Motion in Limine - NO. 5

Motion in Limine - No. 4

Declaration - of Giannie Ramirez in Support of Plaintiff's Motions In Limine for an Order Excluding Defendant Food Forward, Inc.'s Experts, Christopher K. Money and Amy Koellner, from Testifying at Tr

Opposition - Plaintiff's Opposition to Defendant's Motion In Limine No. 4 to Preclude Plaintiff From and Cautioned Regarding Providing Expert Medical Testimony

Opposition - Opposition to Plaintiff's Motion in Limine No. 4

Opposition - Plaintiff's Opposition to Defendant's Motion In Limine No. 10 to Try First the Legal Issue of Wheter Plaintiff's Claim for Negligence and Premises Liability is Bared by the Participant Ac

Reply - Reply to Plaintiff's Opposition to Defendant's Motion in Limine No. 7

Reply - DEFENDANT'S REPLY TO PLAINTIFF'S OPPOSITION TO DEFENDANT'S MOTION IN LIMINE NO.9 TO LIMIT TESTIMONY OF PLAINTIFF'S EXPERT WITNESSES TO THOSE OPINIONS AND CONCLUSIONS TESTIFIED TO IN THEIR DEPO

Reply - DEFENDANTS REPLY TO PLAINTIFF'S OPPOSITION TO DEFENDANT'S MOTION IN LIMINE NO.8 TO EXCLUDE EVIDENCE OF MEDICAL BILLS EXCEPT AS TO THOSE AMOUNTS PAID; DECLARATION WEYD-ANNE MILLER

Reply - DEFENDANT'S REPLY TO PLAINTIFF'S OPPOSITION TO DEFENDANT'S AMENDED MOTION IN LIMINE NO.3 TO PRECLUDE ANY MENTION OF SUBSIQUENT REMEDIAL MEASURES OF FOOD FORWARD AND EMPLOYEES

Opposition - DEFENDANT'S OPPOSITION TO PLAINTIFF'S MOTION IN LIMINE NO.5 EXCLUDING DEFENDANT'S EXPERT, AMY KOELLNER, FRON TESTIFYING AT TRIAL

Reply - DEFENDANT'S REPLY TO PLAINTIFF'S OPPOSITION TO DEFENDANT'S MOTION IN LIMINE NO. 10, TO FIRST TRY THE LEGAL ISSUED ON WHETHER PLAINTIFF'S CLAIM FOR NEGLIGENCE AND PREMISES LIABILITY IS BARED BY

Reply - Reply to Plaintiff's Opposition to Defendant's Motion in Limine No. 4

Reply - to Plaintiff's Opposition to Defendant's Motion in Limine #5, to Preclude Plaintiff from Showing to the Jury any Demonstrative Evidence During Voir Dire, Opening Statements, or Trial Without F

Notice - Notice of withdrawal of defendant's motion in limine no. 6

Notice - Notice of withdrawal of defendant's motion in limine no. 1

Motion in Limine - Defendant's Motion in Limine No. 12; Proposed Order

Motion in Limine - Defendant's Motion in Limine No. 13; Proposed Order

Motion in Limine - Amended Defendant's Motion in Limine No. 13; Proposed Order

Motion in Limine - DEFENDANT'S MOTION IN LIMINE NO. 12 PRECLUDE PLAINTIFF'S PERCIPIENT WITNESSES FROM AND CAUTIONED REGARDING PROVIDING EXPERT MEDICAL TESTIMONY; PROPOSED ORDER

Motion in Limine - DEFENDANT'S MOTION IN LIMINE NO. 13 Exclude Plaintiff's exhibit 14 and 15 ABSENT A 402 HEARING TO ESTABLISH FOUNDATION;[PROPOSED] ORDER

Other - - AMENDED DEFENDANT'S MOTION IN LIMINE NO. 13 EXCLUDE PLAINTIFF'S EXHIBIT 14 AND 15 ABSENT A 402 HEARING TO ESTABLISH FOUNDATION; PROPOSED ORDER

Opposition - PLAINTIFF'S OPPOSITION TO DEFENDANT'S MOTION IN LIMINE NO. 13 TO EXCLUDE PLAINTIFF'S EXHIBIT NOS. 14 AND 15

COMPLAINT FOR INJURY 1. NEGLIGENCE 2. PREMISE LIABILITY

FOOD FORWARD, INC.'S CROSSCOMPLAINT AGAINST JAMES ROBERT BIRKENSHAW AKA J.J. BIRKENSHAW; THE JAMES R BIRKENSHAW TRUST; ANN BIRKENSHAW AKA JJ BIRKENSHAW, ETC

Summons on Cross Complaint -

FOOD FORWARD, INC.'S ANSWER TO COMPLAINT

NOTICE OF DEMURRER AND DEMURRER TO COMPLAINT; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF

DECLARATION OF MAX WELLMAN IN SUPPORT OF DEMURRER TO COMPLAINT

CROSS-COMPLAINT AGAINST FOOD FORWARD, INC.

RULING RE: DEFENDANTS' DEMURRER TO PLAINTIFF'S COMPLAINT

FOOD FORWARD, INC.'S ANSWER TO JAMES R. BIRKENSHAW; JJ BIRKENSHAW; AND J&J BIRKENSHAW TRUST'S CROSS-COMPLAINT

DEFENDANT ANN BIRKENSHAW AKA JJ BIRKENSHAW'S EX PARTE APPLICATION FOR ORDER DISMISSING ACTION FOR FAILURE TO TIMELY AMEND COMPLAINT AFTER DEMURRER WAS SUSTAINED WITH LEAVE TO AMEND; DECLARATION OF BRE

Complaint

Cross-Complaint

Answer

Summons

Notice of Lien

Notice

Cross-Complaint

Declaration

Demurrer

Notice

Reply to Opposition

Opposition Document

Minute order entered: 2017-03-24 00:00:00

Order

Partial Dismissal(not entire case)

Answer to Cross-Complaint

Notice of Ruling

Informal Discovery Conference Form for Personal Injury Courts

Minute order entered: 2017-05-23 00:00:00

Statement of Facts

Motion to Compel

Proof-Personal Service

Minute order entered: 2017-06-28 00:00:00

Minute order entered: 2017-06-26 00:00:00

Order

Notice Re: Continuance of Hearing and Order

Application for Determination of Good Faith Settlement

Request for Judicial Notice

Association of Attorney

Partial Dismissal (w/o Prejudice)

Notice of Change of Address or Other Contact Information

Opposition Document

Stipulation

[Proposed Order] and Stipulation to Continue Trial, FSC (and Related Motion/Discovery Dates) Personal Injury Courts Only (Central District)

Declaration

Minute order entered: 2018-01-26 00:00:00

Ex-Parte Application

Notice

[Proposed Order] and Stipulation to Continue Trial, FSC (and Related Motion/Discovery Dates) Personal Injury Courts Only (Central District)

Motion for Summary Judgment

Declaration

Request

Miscellaneous-Other

Proof of Service (not Summons and Complaint)

Notice of Change of Address or Other Contact Information

Reply/Response

Objection

Declaration

Opposition Document

Order

Minute order entered: 2018-06-13 00:00:00

Ex-Parte Application

Order

Minute order entered: 2018-07-31 00:00:00

Motion in Limine

Motion in Limine #2 to Exclude any and all References to Plaintiff's Prior Drug and Alcohol Use

Motion in Limine (Defendant's No. 2)

Motion in Limine (Defendant's No. 3)

Motion in Limine (Defendants' motion in LIMINE#1)

Motion in Limine (Defendant's no. 1)

Opposition (Defendants opposition to plaintiffs motion in limine no.1)

Joint Exhibit List

Joint Statement of the Case

Plaintiff's Opposition to Defendant's Motion In Limine No. 3 To Preclude Any Mention Of Subsequent remedial Measures Of Defendant...

Opposition (to Defendant's Ex Parte Application to Continue Trial;)

Request to Allow a Voir Dire Without Pre-Set Time Limits and to Permit Mini-Opening Statements; Memorandum of Points and Authorities

Joint Stipulation to Exclude Any and All References to Plaintiff's Felony Convictions and to the Fact that Plaintiff is the Ex-wife/widow of Rick James

Joint Witness List

Plaintiff's Opposition to defendant's Motion In Limine No. 2 To Preclude Any Mention Of an Actual Or Potential Dollar Amount of Damamges

Notice of Lodging (Of Out- Of-State Case Law)

Ex Parte Application (to Continue the Trial and Final Status Conference Date;)

Motion in Limine (NO. 3)

Minute Order ((Ex-Parte Proceedings to Continue the Trial and Final Status C...))

Plaintiff's Opposition to Defendant's Motion In Limine No. 1 To Preclude Plaintiff And All Witnesses Called On Plaintiff's Behalf...

Defendant's Motion In Limine No. 4 Preclude Plaintiff From and Cautioned Regarding Providing Expert Medical Testimony...

Defendant's motion In Limine No 7 To Exclude Evidence, Witnesses, and Documents Not Disclosed In Discovery Responses...

Defendant's Motion In Limine No.6 Preclude Plaintiff and/or Any Witness Called On Plaintiff's Behalf Be Ordered...

Defendant's Opposition to Plaintiff's Motion In Limine no. 2

Defendant's Motion In Limine No.5 Preclude Plaintiff From showing to the Jury Any Demonstrative Evidence During Voir Dire...

Minute Order ((Final Status Conference))

Defendant's Motion In Limine No.9 To Limit testimony of Plaintiff's Expert Witness to Those Opinions and Conclusions Testified to in Their Depositions...

Defendant's Motion In Limine No. 8 To Exclude Evidence of Medical Bills Except As to Those Amounts Paid...

Minute order entered: 2018-10-09 00:00:00

Notice (Defendant Food Forward Inc.'s Notice of Association Of Counsel)

Defendant's Motion In Limine No. 10 To First Try the Legal Issue of Whether Plaintiff's Claim for Negligence and Premises Liability Is Bared by the Participant...

Other - (Joint Statement Of The Case)

Defendant's Motion In Limine No. 11 Exclude Any And All Evidence Of Osha's Agricultural Safety Fact Sheet; [Proposed] Order

Other - (- Joint Witness List)

Defendant's Opposition To Plaintiff's Motion In Limine No. 3

Other - (- Joint Exhibit List)

Other - (- Joint [Proposed] List Of Jury Instructions)

Declaration (Gianne Ramirez)

Reply (DEFENDANTS REPLY TO PLAINTIFF'S OPPOSITION RTO DEFENDANTS MOTION IN LIMINE NO. 2)

Declaration (Weyd-Anne Miller)

Trial Brief

Opposition (to ex parte to exclude Christopher Money from testifying)

Ex Parte Application (For an order excluding Christopher K. Money from testifying at trial)

Defendant's Amended Motion in Limine No.3 to Preclude any Mentions of Subsequent Remedial Measures of Food Forward and Employees

Ex Parte Application (for an order excluding defendant Food Forward, In's expert, Amy Koellner, from testifying at trial)

Opposition (to ex parte application to exclude Amy Koellner from testifying)

Minute Order ((Plaintiff's ex parte application for an order excluding defen...))

Order (RE: DEFENDANTS AMENDED MOTION IN LIMINE 3)

Opposition (Plaintiff's Opposition to Defendant's Motion In Limine No. 10 to Try First the Legal Issue of Wheter Plaintiff's Claim for Negligence and Premises Liability is Bared by the Participant Acknowledgment and Agreement)

Opposition (Plaintiff's Opposition to Defendant's Motion In Limine No. 9 to Limit Testimony of Plaintiff's Expert Witnesses to Those Opinions in Their Deposition)

Motion in Limine (No. 5)

Opposition (Plaintiff's Opposition to Defendant's Amended Motion In Limine No.3 to Preclude Any Mention of Subsequent Remedial Measures of Defendant and Defendant's Employees)

Opposition (Plaintiff's Opposition to Defendant's Motion In Limine No. 7 to Exclude Evidence Not Disclosed In Discovery)

Opposition (Plaintiff's Opposition to Defendant's Motion In Limine No. 4 to Preclude Plaintiff From and Cautioned Regarding Providing Expert Medical Testimony)

Motion in Limine (No. 4)

Plaintiff's opposition to defendant's motion in limine no. 5 to preclude any demonstrative evidence during voir dire, opening statements or trial

Trial Brief (Tanya Hijazi's Trial Brief)

Opposition (Plaintiff's Opposition to Defendant's Motion In Limine No . 8 to Exclude Evidence of Medical Bills Except as to Those Amounts Paid)

Plaintiff's opposition to defendant's motion in limine no. 11 to exclude any and all evidence of Osha's Agricultural fact sheet

Minute Order ((Final Status Conference))

Opposition (to Plaintiff's Motion in Limine No. 4)

to Plaintiff's Opposition to Defendant's Motion in Limine #5, to Preclude Plaintiff from Showing to the Jury any Demonstrative Evidence During Voir Dire, Opening Statements, or Trial Without First Showing the Proposed to all Counsel Prior to the Start

Reply (to Plaintiff's Opposition to Defendant's Motion in Limine No. 7)

to Plaintiff's Opposition to Defendant's Motion in Limine #11, Exclude any and all Evidence of Osha's Agricultural Safety FAct Sheet

Reply (to Plaintiff's Opposition to Defendant's Motion in Limine No. 4)

Notice (Of Association Of Cousel)

Other - (Election to Forgo Affidavit (CCP Sec. 170.6))

Defendant's Motion in Limine No. 13; Proposed Order

Amended Defendant's Motion in Limine No. 13; Proposed Order

Trial Transfer Order (to Judge Peter Mirich, Department S29, Long Beach)

Notice (of withdrawal of defendant's motion in limine no. 1)

Minute Order ((Jury Trial))

TRIAL BRIEF ON ADMISSIBILITY OF THE WAIVER/RELEASE

Defendant's Motion in Limine No. 12; Proposed Order

Minute Order ((Jury Trial))

Challenge To Judicial Officer - Peremptory (170.6)

Notice (of withdrawal of defendant's motion in limine no. 6)

Minute Order ((Jury Trial))

Minute order entered: 2018-10-19 00:00:00

DEFENDANT'S MOTION IN LIMINE NO. 13 Exclude Plaintiff's exhibit 14 and 15 ABSENT A 402 HEARING TO ESTABLISH FOUNDATION;[PROPOSED] ORDER

DEFENDANT'S MOTION IN LIMINE NO. 12 PRECLUDE PLAINTIFF'S PERCIPIENT WITNESSES FROM AND CAUTIONED REGARDING PROVIDING EXPERT MEDICAL TESTIMONY; PROPOSED ORDER

Order Appointing Court Approved Reporter as Official Reporter Pro Tempore (CSR: CELINDA ALIGADA, NO. 13724)

AMENDED DEFENDANT'S MOTION IN LIMINE NO. 13 EXCLUDE PLAINTIFF'S EXHIBIT 14 AND 15 ABSENT A 402 HEARING TO ESTABLISH FOUNDATION; PROPOSED ORDER

Minute Order ((Jury Trial))

DEFENDANT'S OPPOSITION TO PLAINTIFF'S CONTENTION A NON-DELEGABLE DUTY OF SAFETY AND NEGLIGENCE PRECLUDE THE APPLICABILITY OF THE RELEASE AND EXPRESS ASSUMPTION OF THE RISK SIGNED BY PLAINTIFF.

PLAINTIFF'S OPPOSITION TO DEFENDANT'S MOTION IN LIMINE NO. 13 TO EXCLUDE PLAINTIFF'S EXHIBIT NOS. 14 AND 15

DEFENDANT'S BRIEF IN SUPPORT OF ADMISSIBILITY OF THE RELEASE

DEFENDANT'S BRIEF IN SUPPORT OF BIFURCATION

Minute Order ((Jury Trial))

Minute Order ((Jury Trial In Progress))

Request for Dismissal

Minute Order ((Jury Trial In progress))

PLAINTIFF'S TRIAL BRIEF ON THE ISSUE OF CAL-OSHA APPLICABILITY TO NON-EMPLOYEES

DEFENDANT'S BRIEF IN OPPOSITION OF ADMISSIBILITY OF OSHA APPLICABILITY TO NON-EMPLOYERS.

PLAINTIFF'S TRIAL BRIEF ON THE ISSUE OF CACI NO. 472 AND THE ADMISSIBILITY OF THE SIGNED WAIVER

Request for Dismissal

DEFENDANT'S SECOND BRIEF IN SUPPORT OF ADMISSIBILITY OF THE RELEASE

Minute Order ((Jury Trial in progress))

Minute Order ((Jury Trial in progress))

Minute Order ((Order to Show Cause Re: Dismissal (Settlement)))