Herman Birdine Vs Ford Motor Company

PLAINTIFF HERMAN BIRDINE'S NOTICE OF MOTION AND MOTION TO COMPEL THE DEPOSITION OF DEFENDANT FORD MOTOR COMPANY'S PERSON[S) MOST KNOWLEDGEABLE, WITH PRODUCTION OF DOCUMENTS; MEMORANDUM OF POINTS & AUT

DECLARATION OF MARY LYNN ARENS IN SUPPORT OF DEFENDANT FORD MOTOR COMPANY'S OPPOSITIONS TO PLAINTIFF'S MOTIONS TO COMPEL THE DEPOSITION OF DEFENDANT'S PERSON MOST QUALIFIED AND REQUEST FOR PRODUCTION

PLAINTIFF HERMAN BIRDINE'S REPLY TO DEFENDANT FORD MOTOR COMPANY'S OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL THE DEPOSITION OF DEFENDANT FORD MOTOR COMPANY'S PERSON(S) MOST KNOWLEDGEABLE, WITH PRODUC

RULING: PLAINTIFF HERMAN BIRDINE'S MOTION TO COMPEL THE DEPOSITION OF DEFENDANT FORD MOTOR COMPANY'S PMK, WITH PRODUCTION OF DOCUMENTS, IS GRANTED (IN PART).

MOTION IN LIMINE NO.10 DEFENDANT'S MOTION IN LIMINE NO. 10 TO EXCLUDE EVIDENCE OR REFERENCE TO VARGAS LAWSUIT OR OTHER UNRELATED CLAIMS, LITIGATION AND ALLEGED PROBLEMS; ETC.

MOTION IN LIMINE NO.9 DEFENDANT'S MOTION IN LIMINE NO.9 TO EXCLUDE ANY ARGUMENT, MENTION OR REFERENCE TO THE TERM "LEMON LAW," AND THE WORD "LEMON"; ETC.

MOTION IN LIMINE NO. 7 DEFENDANT FORD MOTOR COMPANY'S MOTION IN LIMINE NO.7 TO EXCLUDE EVIDENCE AND REFERENCE TO NON-RECOVERABLE INCIDENTAL AND CONSEQUENTIAL DAMAGES; ETC.

MOTION IN LIMINE NO. 1 DEFENDANT'S MOTION IN LIMINE NO. I TO EXCLUDE ITEMS NEVER PRESENTED OR PRESENTED JUST ONCE WITHIN THE EXPRESS WARRANTY; ETC.

MOTION IN LIMINE NO. 2 DEFENDANT'S MOTION IN LIMINE NO.2 TO EXCLUDE EVIDENCE OF A DESIGN DEFECT AS A BASIS FOR BREACH OF EXPRESS WARRANTY; ETC.

MOTION IN LIMINE NO. 8 DEFENDANT FORD MOTOR COMPANY'S MOTION IN LIMINE NO. 8 TO EXCLUDE EVIDENCE NOT PRODUCED IN DISCOVERY; ETC.

MOTION IN LIMINE NO 6 DEFENDANT'S MOTION IN LIMINE NO.6 TO EXCLUDE GOLDEN RULE ARGUMENT; [PROPOSED] ORDER

MOTION IN LIMINE NO.11 DEFENDANT'S MOTION IN LIMINE NO. 11 TO EXCLUDE REFERENCE TO EMOTIONAL DISTRESS DAMAGES; [PROPOSED] ORDER

MOTION IN LIMINE NO. 5 DEFENDANT'S MOTION IN LIMINE NO. 5 TO EXCLUDE TECHNICAL. SERVICE BULLETINS, CAMPAIGNS AND RECALLS; DECLARATION OF MARY LYNN ARENS; [PROPOSED] ORDER

MOTION IN LIMINE NO.3 DEFENDANT'S MOTION IN LIMINE NO. 3 TO EXCLUDE EVIDENCE, ARGUMENT OR TESTIMONY THAT THE REPAIR ORDERS ALONE SUBSTANTIALLY IMPAIR THE USE, VALUE OR SAFETY OF THE VEHICLE; (PROPOSED

MOTION IN LIMINE NO. 4 DEFENDANT'S MOTION IN LIMINE NO. 4 TO EXCLUDE TESTIMONY THAT PLAINTIFF'S VEHICLE WAS "SUBSTANTIALLY IMPAIRED"; ETC.

Complaint

Proof-Service/Summons

Notice of Case Management Conference

Case Management Statement

Case Management Statement

Notice of Case Management Conference

Notice of Related Case

Motion to Compel

Notice of Settlement

Motion in Limine

Reply/Response

Opposition Document

Declaration

Order

Request for Dismissal

Notice of Settlement