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Law Office Of ELECTRONICALLY FILED
MICHAEL P. RING Superior Court of California
AND ASSOCIATES County of Santa Barbara
Michael P. Ring, State Bar #95922 Darrel E. Parker, Executive Officer
Iris L. M. Ring, State Bar #298179 7/6/2016 3:16:48 PM
1234 Santa Barbara Street By: Terri Chavez, Deputy
Santa Barbara, CA 93101
(805) 564-2333
ATTORNEYS FOR PATSY MOLER
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SANTA BARBARA
ANACAPA DIVISION
PATSY MOLER, Case No. 1417847
Plaintiff, PATSY MOLER'S REQUESTED LIST
OF JURY INSTRUCTIONS
v.
DATE: 7/13/16
Chris Hulme, individually and dba TIME: 11:30 A.M.
Clearview Industries, Inc., Jennifer Hulme, DEPT: SB1
individually and dba Clearview Industries,
Inc., and DOES 1 through 10, inclusive
Defendants. (Assigned to Hon. James E. Herman)
And Related Cross-Actions
Patsy Moler respectfully requests this court to give the following numbered Judicial Council
of California Civil Jury Instructions, and the additional instructions set forth below, and any further
or additional instructions that may be subsequently requested submits the following List Of Jury
Instructions.
BAJI:
0.50, 1.00, 1.00.1, L00.5, 1.01, 1.02, 1.04, 1.10, 1.20, 1.21, 1.23, 1.30, 2.00, 2.01,
2.02, 2.03, 2.04, 2.05, 2.06, 2.07, 2.08, 2.20, 2.21, 2.22, 2.25, 2.40, 2.41, 2.42, 2.60,
2.62, 3.52, 6.37, 10.55, 10.57, 10.82, 10.85, 10.86, 10.90, 10.92, 12.30, 12.31, 12.32,
12.35, 12.36, 12.37, 12.51, 12.52, 12.56, 12.57, 12.99, 13.00, 13.03, 13.30, 14.62,
14.71, 14.71.2, 14.72.1 14.72.2, 14.73, 14.73.1, 14.74, 15.03, 15.20, 15.21, 15.22, 15.30,
-1-
PATSY MOLER'S REQUESTED BAB & CACI JURY INSTRUCTIONS
15.31, 15.33, 15.35, 15.40, 15.50, 15.51, 15.52, 15.53.1, 15.53.2, 15.54, 15.55, 16.50,
16.50.1, 16.50.2, 16.81, 16.82.
, 328, 338, 350, 351, 354, 358, 370,
371, 372, 1900, 1901, 1902, 1904, 1906, 1907, 1908, 1923, 1924, 2100, 2102, 3114, 3115, 3116,
3242, 3243, 3900, 3902, 3903, 3903F, 3903G, 3925, 3934, 3940, 3941, 3942, 3945, 3946, 3947,
5012, 5016, 5018, 5019, 5020, 5021, 5090.
Respectfully submitted,
LAW
A OFFICE
FIEO OF MICHAEL
IHE P.
.RNRING & ASSOC.
SO.
Dated: July 6, 2016
MICHAEL P.
ATTORNEY FOR 'LAINTI
--2-
2-
PATSY MOLER'S REQUESTED BAJI & CACI JURY INSTRUCTIONS
PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF SANTA BARBARA
I am employed in the County of Santa Barbara, State of California. I am over the age of 18
and not a party to the within action; my business address is 1234 Santa Barbara Street, Santa Barbara,
California, 93101.
On July 6, 2016, I served the foregoing document described as PATSY MOLER'S
REQUESTED BAJI & CACI JURY INSTRUCTIONS on the interested parties in this action
XX by placing the original XX a true copy thereof addressed as follows:
JEFFREY M. BENNION BRIAN K. FINDLEY
2869 INDIA ST MULLIGAN, BANHAM & FINDLEY
SAN DIEGO, CA 92103 2442 Fourth Avenue, Suite 100
jeff@jbennionlaw.com
(via email only per agreement of the parties) San Diego, CA 92101
(via email only per agreement of the parties)
(BY FEDERAL EXPRESS OVERNIGHT DELIVERY) I caused such documents to be
picked up by Federal Express at 1234 Santa Barbara St., Santa Barbara, California, 93101, in a box
designated by Federal Express for overnight delivery, with delivery fees provided for, addressed to
the person on whom it is to be served.
(BY FAX) I caused the above-referenced document(s) to be sent via facsimile to the above-
named persons at the following facsimile number:
XX (BY ELECTRONIC SERVICE) the electronic address where I served this is
jeff@jbennionlaw.com.
(BY PLACING FOR COLLECTION AND MAILING) I placed the above-mentioned
document(s) in sealed envelope(s) addressed as set forth above, and placed the envelope(s) for
collection and mailing following ordinary business practices. I am readily familiar with the firm's
practice for collection and processing of correspondence for mailing with the United States Postal
Service. Under that practice it would be deposited with the U.S. Postal Service on that same day
with postage thereon fully prepaid at 1234 Santa Barbara Street, Santa Barbara, CA 93101 in the
ordinary course of business.
XX (STATE) I declare under penalty of perjury under the laws of the State of California that the
above is true and correct.
Executed on July 6, 2016, at Santa Barbara, California.
MICHAEL P. RING
Type or Print Name
PROOF OF SERVICE
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Law Office Of ELECTRONICALLY FILED MICHAEL P. RING Superior Court of California AND ASSOCIATES County of Santa Barbara Michael P. Ring, State Bar #95922 Darrel E. Parker, Executive Officer Iris L. M. Ring, State Bar #298179 7/6/2016 3:16:48 PM 1234 Santa Barbara Street By: Terri Chavez, Deputy Santa Barbara, CA 93101 (805) 564-2333 ATTORNEYS FOR PATSY MOLER SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SANTA BARBARA ANACAPA DIVISION PATSY MOLER, Case No. 1417847 Plaintiff, PATSY MOLER'S REQUESTED LIST OF JURY INSTRUCTIONS v. DATE: 7/13/16 Chris Hulme, individually and dba TIME: 11:30 A.M. Clearview Industries, Inc., Jennifer Hulme, DEPT: SB1 individually and dba Clearview Industries, Inc., and DOES 1 through 10, inclusive Defendants. (Assigned to Hon. James E. Herman) And Related Cross-Actions Patsy Moler respectfully requests this court to give the following numbered Judicial Council of California Civil Jury Instructions, and the additional instructions set forth below, and any further or additional instructions that may be subsequently requested submits the following List Of Jury Instructions. BAJI: 0.50, 1.00, 1.00.1, L00.5, 1.01, 1.02, 1.04, 1.10, 1.20, 1.21, 1.23, 1.30, 2.00, 2.01, 2.02, 2.03, 2.04, 2.05, 2.06, 2.07, 2.08, 2.20, 2.21, 2.22, 2.25, 2.40, 2.41, 2.42, 2.60, 2.62, 3.52, 6.37, 10.55, 10.57, 10.82, 10.85, 10.86, 10.90, 10.92, 12.30, 12.31, 12.32, 12.35, 12.36, 12.37, 12.51, 12.52, 12.56, 12.57, 12.99, 13.00, 13.03, 13.30, 14.62, 14.71, 14.71.2, 14.72.1 14.72.2, 14.73, 14.73.1, 14.74, 15.03, 15.20, 15.21, 15.22, 15.30, -1- PATSY MOLER'S REQUESTED BAB & CACI JURY INSTRUCTIONS 15.31, 15.33, 15.35, 15.40, 15.50, 15.51, 15.52, 15.53.1, 15.53.2, 15.54, 15.55, 16.50, 16.50.1, 16.50.2, 16.81, 16.82. , 328, 338, 350, 351, 354, 358, 370, 371, 372, 1900, 1901, 1902, 1904, 1906, 1907, 1908, 1923, 1924, 2100, 2102, 3114, 3115, 3116, 3242, 3243, 3900, 3902, 3903, 3903F, 3903G, 3925, 3934, 3940, 3941, 3942, 3945, 3946, 3947, 5012, 5016, 5018, 5019, 5020, 5021, 5090. Respectfully submitted, LAW A OFFICE FIEO OF MICHAEL IHE P. .RNRING & ASSOC. SO. Dated: July 6, 2016 MICHAEL P. ATTORNEY FOR 'LAINTI --2- 2- PATSY MOLER'S REQUESTED BAJI & CACI JURY INSTRUCTIONS PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF SANTA BARBARA I am employed in the County of Santa Barbara, State of California. I am over the age of 18 and not a party to the within action; my business address is 1234 Santa Barbara Street, Santa Barbara, California, 93101. On July 6, 2016, I served the foregoing document described as PATSY MOLER'S REQUESTED BAJI & CACI JURY INSTRUCTIONS on the interested parties in this action XX by placing the original XX a true copy thereof addressed as follows: JEFFREY M. BENNION BRIAN K. FINDLEY 2869 INDIA ST MULLIGAN, BANHAM & FINDLEY SAN DIEGO, CA 92103 2442 Fourth Avenue, Suite 100 jeff@jbennionlaw.com (via email only per agreement of the parties) San Diego, CA 92101 (via email only per agreement of the parties) (BY FEDERAL EXPRESS OVERNIGHT DELIVERY) I caused such documents to be picked up by Federal Express at 1234 Santa Barbara St., Santa Barbara, California, 93101, in a box designated by Federal Express for overnight delivery, with delivery fees provided for, addressed to the person on whom it is to be served. (BY FAX) I caused the above-referenced document(s) to be sent via facsimile to the above- named persons at the following facsimile number: XX (BY ELECTRONIC SERVICE) the electronic address where I served this is jeff@jbennionlaw.com. (BY PLACING FOR COLLECTION AND MAILING) I placed the above-mentioned document(s) in sealed envelope(s) addressed as set forth above, and placed the envelope(s) for collection and mailing following ordinary business practices. I am readily familiar with the firm's practice for collection and processing of correspondence for mailing with the United States Postal Service. Under that practice it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid at 1234 Santa Barbara Street, Santa Barbara, CA 93101 in the ordinary course of business. XX (STATE) I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on July 6, 2016, at Santa Barbara, California. MICHAEL P. RING Type or Print Name PROOF OF SERVICE