On May 08, 2008 a Motion,Ex Parte was filed involving a dispute between Pique, Frederick, Pique, Godofredo, Pique, Gregory, Pique, Rosita, Sanchez, Marlene, and All Asbestos Defendants, Allis-Chalmers Corporation Product Liability Trust, Asbestos Defendants, Borg-Warner Corporation By Its Successor In, Carlisle Corporation, Caterpillar, Inc., Cbs Corporation, A Delaware Corporation, F K A, Cbs Corporation (Fka Viacom Inc., Fka, Coltec Industries, Inc., Crane Co., Csk Auto, Inc., Cummins Inc., Daimler Trucks North America Llc, Dana Companies, Llc, Deere & Company, Designated Defense Counsel, Does 1-8500, Douglass Insulation Company, Inc., Federal-Mogul Asbestos Personal Injury, Ford Motor Company, Foster Wheeler Llc, Garlock Sealing Technologies, Llc, General Motors Corporation, Heil Co., Honeywell International, Inc., Honeywell International Inc., F K A Alliedsignal,, Hopeman Brothers, Inc., Imo Industries Inc., J.T. Thorpe & Son, Inc., Leslie Controls, Inc., Macarthur Company, Metropolitan Life Insurance Company, Navistar, Inc., Navistar, Inc.,, Paccar Inc., Parker Hannifin Corporation, Plant Insulation Company, Pneumo Abex Llc, Pneumo Abex Llc, Successor-In-Interest, Quintec Industries, Inc., Rapid-American Corporation, Scandura, Inc., The Goodyear Tire & Rubber Company, The Heil Co.,, Thomas Dee Engineering Co., Inc., Thomas Dee Engineering Company, Tube City Ims Corporation, Utility Trailer Manufacturing, Utility Trailer Manufacturing Company, Western Asbestos Company, Western Macarthur Company, for civil in the District Court of San Francisco County.
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28 LANKFORD CRAWFORD MORENO LLP. ATTORNEYS ar LAW PAUL V. LANKFORD (State Bar No. 181506) plankford@Iclaw.com PAUL LANNUS (State Bar No. 192551) plannus@lelaw.com LANKFORD CRAWFORD MORENO LLP 1850 Mt. Diablo Blvd., Suite 600 Walnut Creek, CA 94596 Telephone: 925.300.3520 Facsimile: 925.300.3386 Attomeys for Defendant FORD MOTOR COMPANY ELECTRONICALLY FILED Superior Court of California, County of San Francisco JAN 25 2012 Clerk of the Court BY: JUDITH NUNEZ Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO ROSITA PIQUE, as Wrongful Death Heir, and as Successor-In-Interest to GODOFREDO PIQUE, Deceased; and MARLENE SANCHEZ, GREGORY PIQUE, FREDERICK PIQUE, as Legal Heirs of GODOFREDO PIQUE, Deceased, *PlaintifY, v. ASBESTOS DEFENDANTS (B#P), Defendants. ASBESTOS CASE No. CGC 08-274659 DEFENDANT FORD MOTOR COMPANY’S MOTION IN LIMINE FoR THE Court To PRE-CLEAR DEMONSTRATIVE AND PHYSICAL EVIDENCE [MIL #51] * The use of the term “plaintiff as used herein refers to the plaintiff in a personal injury action and the decedent in a wrongful death action; and the use of “plaintiff” shall refer to both plaintiff in the singular and plural, as appropriate. CASE NO. CGC 08-27465928 LANKFORD CRAWFORD MORENO LLP. ATTORNEYS ar LAW The above-named defendant (hereinafter “Defendant”) hereby moves the court, in limine, prior to trial and before the selection of a jury, for an Order that all parties, either witnesses and their attorneys are prohibited from using in the presence of the jury, or in any way displaying to the jury, any demonstrative or other physical evidence without first having had the court rule specifically upon the admissibility or use of such evidence. This motion is made on the grounds that Defendant will suffer undue prejudice unless the other parties, their witnesses and their attorneys are prohibited from using or in any way displaying to or in the presence of the jury any demonstrative or other physical evidence that has not previously been identified and ruled upon as admissible by the court. Evidence Code § 352. Thus, the granting of Defendant’s motion will avoid possible error and/or prejudice to Defendant. Dated: December 14, 2011 LANKFORD CRAWFORD MORENO LLP "% ° my (seta wy Hi PAUL V. LANKFORD PAUL LANNUS Attorneys for Defendant FORD MOTOR COMPANY DEFENDANT FORD MOTOR COMPANY'S MOTION IN LIMINE FOR THE COURT TO PRE-CLEAR DEMONSTRATIVE AND PHYSICAL EVIDENCE, [MELHSt]