On May 20, 2009 a Party Discovery was filed involving a dispute between Juelch, Joyce, Juelch Sr, Norman, and 3M Company, 84 Lumber Company, 84 Lumber Company, A Limited Partnership, All Asbestos Defendants, Allis-Chalmers Corporation Product Liability Trust, Asbestos Defendants, Cbs Corporation, A Delaware Corporation, F K A, Chevron U.S.A. Inc., Consolidated Insulation, Inc., Csk Auto, Inc., Dillingham Construction N.A., Inc., Does 1-8500, Douglass Insulation Company, Inc., Garlock Sealing Technologies, Llc, General Electric Company, Genuine Parts Company, Hamilton Materials, Inc., J.T. Thorpe & Son, Inc., Kaiser Gypsum Company, Inc., Metalclad Insulation Corporation, Oscar E. Erickson, Inc., Pacific Gas And Electric Company, Pacipic Bell Telephone Company, Parker Hannifin Corporation, Quintec Industries, Inc., Redwood Plumbing Co., Inc., Santa Fe Braun, Inc., Sequoia Ventures Inc., Shell Oil Company, Thomas Dee Engineering Company, Timec Company, Inc., Tosco Refining Company, Inc., Union Carbide Corporation, Union Oil Company Of California, Unocal Corporation, for ASBESTOS in the District Court of San Francisco County.
For full print and download access, please subscribe at https://www.trellis.law/.
Please wait a moment while we load this page.
Preview
28 McKenna LONG & ALORIDGE 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 41st Floor Superior Court of California, San Francisco, CA 94111 County of San Francisco Telephone: (415) 267-4000 R 13 2010 Facsimile: (415) 267-4198 APF ‘of the Court BY: CHRISTLE ARRIOLA Attorneys for Defendant Deputy Clerk METALCLAD INSULATION CORPORATION SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO JOYCE JUELCH and CASE No. CGC-09-274212 NORMAN JUELCH, SR., DEFENDANT’S MOTION EN LIMINE FOR PRE- DISCLOSURE OF LIVE WITNESSES, WITNESS ‘TRANSCRIPTS AND DOCUMENTS PRIOR TO Plaintiffs, PRESENTATION AT TRIAL [MIL 3} v. TRIAL DATE: APRIL 5, 2010 DEPT.: 604 ASBESTOS DEFENDANTS, (BP), ef al, JUDGE: HONORABLE MaRLA 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: (1) That each party advise all other parties, in writing by facsimile or personal service in advance, of each live witness and exhibits to be used by each witness that the party will present at trial, as follows: ‘WITNESS DISCLOSURE BY PRIOR Monday Thursday by 4 pm -f- DEFENCANT'S MOTION IN LIMINE FOR PRE-DISCLOSURE OF LIVE WITNESSES, WITNESS TRANSCRIPTS AND DOCUMENTS PRIOR TO PRESENTATION AT TRIAL [MIL 3] SF.27418495.tye eB DH HW RF YW Dm BON tees we N= SD 2 Oe NY DW BF OW YD =| S 28 McKenna LONG & ALORIDGR LLP ATTORNEYS AT Law SAN Francis Tuesday Friday by 4 pm Wednesday Friday by 4 pm Thursday Monday by 4 pm Friday Tuesday by 4 pm (2) That each party provide designated page and line citations of any prior deposition or trial testimony to be presented 72 hours prior to their being read, with the transcript and any exhibits to be made available simultaneously, that objections and counter-designations to such | testimony be provided by opposing counsel within forty-eight (48) hours of receipt of each designation and transcript. | (3) That no documents or prior testimony be specifically referred to, or quoted, by any attomey until the opposing side has had the opportunity to request a hearing on their admissibility, out of the presence of the jury. The above Orders will allow the parties to adequately prepare for this trial. There are i thousands of documents and dozens 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 prejudice. Dated: April 5, 2010 MCKENNA LONG & ALDRIDGE LLP [ua C. “LISA L. OBERG DANIEL B. Hove ALECIA E. COTTON Attomeys for Defendant, METALCLAD INSULATION CORPORATION -2- DEFENDANT'S MOTION IN LIMINE FOR PRE-DISCLOSURE OF LIVE WITNESSES. WITNESS TRANSCRIPTS ANO DOCUMENTS PRIOR TO PRESENTATION AT TRIAL [MIL 3} SF.27418495.1