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  • LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview 
						
                                
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2OTS74.1 107728787

RICHARD D. DUMONT (SBN 107967)

rdumont@selmanbreitman.com ELECTRONICALLY
PAUL J. GAMBA (SBN 146097)
pgamba@selmanbreitman.com F ILE D -
SELMAN BREITMAN LLP Superior Court of California,
33 New Montgomery, Sixth Floor County of San Francisco
San Francisco, CA 94105 OCT 29 2010
Telephone: a1 979-0400 Clerk of the Court
Facsimile: {415} 979-2099 BY: JUANITA D. MURPHY
Deputy Clerk

Attorneys for Defendant
LAMONS GASKET COMPANY

SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO - UNLIMITED JURISDICTION

LOUIS CASTAGNA, Case No. CGC-07-274230
Plaintiff, MOTION IN LIMINE TO REQUIRE
48-HOUR PRE-DISCLOSURE OF
v. WITNESSES AND 72-HOUR PRE-
DISCLOSURE OF DOCUMENTS
ASBESTOS DEFENDANTS (BP), PRIOR TO PRESENTATION AT

TRIAL - Motion in Limine No. 12

Action Filed: June 6, 2007
Trial Date: October 29, 2010

Defendant.

Defendant, LAMONS GASKET COMPANY (hereinafter “Lamons”) hereby
moves this court in limine, prior to trial and before the selection of a jury, for the following
Orders in conjunction with trial of the above-entitled matter.

1 That each party advise all other parties, at least forty-eight (48) hours in
advance of calling each witness that the party will have testify at trial.

2. That each party designate and disclose documents seventy-two (72) hours
prior to seeking to admit the documents into evidence or to elicit testimony from a witness
concerning the document.

3. That no documents be specifically referred to, or quoted, by any attorney

until the opposing side has had the opportunity to request a hearing on their admissibility,

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MOTION EN LIMINE TO REQUIRE 48-HOUR PRE-DISCLOSURE OF WITNESSES AND 72-HOUR PRE-
DISCLOSURE OF DOCUMENTS PRIOR TO PRESENTATION AT TRIAL - MIL NO. 121 | out of the presence of the jury.

2 The above Orders will allow the parties to adequately prepare for this trial. There
are thousands of documents and hundreds of potential witnesses available to all parties.
Many documents and some testimony should be excluded. Disputed evidence should not
be referred to in the presence of the jury until the Court has issued a ruling. Equal
application of the Orders requested would insure a faster trial and would avoid undue

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DATED: October 28, 2010 SELMAN BREITMAN LLP

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od RICHARD D. DUMONT
a 12 PAUL J. GAMBA
ae Attorneys for Defendant
& 7 2B LAMONS GASKET COMPANY
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207574. 107728787 MOTION IN LIMINE TO REQUIRE 48-HOUR PRE-DISCLOSURE OF WITNESSES AND 72-HOUR PRE-
DISCLOSURE OF DOCUMENTS PRIOR TO PRESENTATION AT TRIAL - MIL NO. 122
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207878, 1077.28787

PROOF OF SERVICE BY ELECTRONIC TRANSMISSION

Louis Castagna v. Asbestos Defendants (BP)
San Francisco Superior Court Case No. CGC-07-274230
Defendant; LAMONS GASKET COMPANY
STATE OF CALIFORNIA, COUNTY OF SAN FRANCISCO

I am employed in the County of San Francisco, State of California. I am over the
age of 18 years and am not a party to the within action; my business address is 33 New
Montgomery, Sixth Floor, San Francisco, CA 94105.

On the date shown below, | electronically served the following document(s) via
LexisNexis File & Serve described as MOTION IN LIMINE TO REQUIRE 48-HOUR
PRE-DISCLOSURE OF WITNESSES AND 72-HOUR PRE-DISCLOSURE OF
DOCUMENTS PRIOR TO PRESENTATION AT TRIAL - Motion in Limine No. 12
on the recipients designated on the Transaction Receipt located on the LexisNexis File &
Serve website.

I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.

Executed on October ZS, 2010, at San Francisco, California.

Cyff/ Lilt.

/ /? C¥nthia Elrod

‘

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MOTION IN LIMINE TO REQUIRE 48-HOUR PRE-DISCLOSURE OF WITNESSES AND 72-HOUR PRE-
DISCLOSURE OF DOCUMENTS PRIOR TO PRESENTATION AT TRIAL - MIL NO. 12