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  • JOYCE JUELCH, ET AL VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • JOYCE JUELCH, ET AL VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • JOYCE JUELCH, ET AL VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • JOYCE JUELCH, ET AL VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
						
                                

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28 MCKENNA LONG & ALDRIDGE LLP ATTORNEYS AT LAW SAN FRANCISCO, LISA L. OBERG (BAR NO. 120139) DANIEL B. HOYE (BAR NO. 139683) ALECIA E. COTTON (BAR NO. 252777) MCKENNA LONG & ALDRIDGE LLP ELECTRONICALLY 101 California Street FILED 4ist Floor Superior Court of California, San Francisco, CA 94111 County of San Francisco Telephone: (415) 267-4000 Facsimile: (415) 267-4198 APR A 3 2010 Attorneys for Defendant BY: CHRISTLE ‘Deputy Clerk METALCLAD INSULATION CORPORATION SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO JOYCE JUELCH and Case No. CGC-09-275212 NORMAN JUELCH, SR., DEFENDANT’S MOTION IN LIMINE CONCERNING PUBLICATION OF EXHIBITS TO THE Jury [MIL 5] Plaintiffs, ¥. TRIAL DATE: Aprit 5, 2010 ASBESTOS DEFENDANTS, (BP), ef al., Dept.: 604 JupGe: HONORABLE Mara J. MILLER Defendants. TO PLAINTIFFS AND PLAINTIFFS’ ATTORNEYS OF RECORD: THE ABOVE NAMED DEFENDANT (hereinafter “Defendant”) hereby moves this Court in limine for the following Orders in conjunction with trial of the above-entitled matter. That all exhibits to be shown to a witness be previously marked for identification, reviewed by counsel and approved by the Court. That before an exhibit may be published to the jury by any means, approval must be obtained from the Court prior to jury selection. That after -1- DEFENDANT'S MOTION IN LIMINE CONCERNING PUBLICATION OF EXHIBITS TO THE JURY [MIL 5} S¥:27418498.4oe NY KD AH eb 28 MCKENNA LONC & ALDRIDGE LLP ATYORNEYS AT LAW SAN FRANCISCO provide to the jury during deliberations. would avoid undue prejudice. Dated: — April 5, 2010 the presentation of all evidence the Court determine which exhibits to admit into evidence and The above Orders will allow the parties to adequately prepare for this trial. There are potentially thousands of documents available to all parties, and many documents 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 MCKENNA LONG & ALDRIDGE LLP Log ft Lisa L. OBERG a Danie B.HOYE ALECIA E. COTTON Attorneys for Defendant, METALCLAD INSULATION CORPORATION -2- SF:27418498. 1 DEFENDANT'S MOTION IN LIMINE CONCERNING PUBLICATION OF EXHIBITS TO THE JURY [MIL 5}