Motion,Ex Parte: COMMONWEALTH LAND TITLE INSURANCE COMPANY VS. FEDEX OFFICE AND PRINT SERVICES, INC et al (PROVIDE ACCESS)

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FIDELITY NATIONAL LAW GROUP
HOWARD P. BRODY (SBN 65307)
915 Wilshire Boulevard, Suite 2100

Los Angeles, California 90017
Telephone: (213) 438-4414

Facsimile: (213) 438-4417

Email: howard.brody@fnf.com

Attorneys for Plaintiff,
COMMONWEALTH LAND TITLE
INSURANCE COMPANY

ELECTRONICALLY
FILED

Superior Court of California,
County of San Francisco

06/02/2017
Clerk of the Court
BY:RONNIE OTERO
Deputy Clerk

SUPERIOR COURT FOR THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN FRANCISCO

COMMONWEALTH LAND TITLE
INSURANCE COMPANY,

Plaintiffs,
v.

FEDEX OFFICE AND PRINT SERVICES,
INC.; WINSTON LUM; KAUSHAL
NIROULA; JAY CHANDRAKANT SHAH;
ELVIA PALOMINO; MORAD AFRAIMI;
MELVIN LEE EMERICH; MARTINI &
CHNOOGLE; GRACHELLE LANGUBAN;
MERCHANTS BONDING COMPANY, and
DOES 1-25, inclusive,

Defendants.

CASE NO. CGC-10-503332
(Consolidated for all purposes with CGC-11-
512102)

PLAINTIFF COMMONWEALTH LAND
TITLE INSURANCE COMPANY’S
MOTION IN LIMINE NO. 3 TO
PRECLUDE ALL PARTIES FROM
PRECONDITIONING THE JURY
DURING VOIR DIRE

Trial Date:
Time:
Dept.:

June 12, 2017
9:30 a.m.
206

TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD HEREIN:

PLAINTIFF COMMONWEALTH LAND TITLE INSURANCE COMPANY moves the

Court in imine and prior to the empanelment of a jury, for an order precluding all parties from

engaging in preconditioning of the jury during voir dire.

‘if
‘It

1

PLAINTIFF COMMONWEALTH LAND TITLE INSURANCE COMPANY'S MOTION IN LIMINE NO. 3 TO PRECLUDE ALL
PARTIES FROM PRECONDITIONING THE JURY DURING VOIR DIRE1 This motion is based on the attached memorandum of points and authorities, the papers,
2 | records, and files herein, and on such other documentary and oral evidence as the court may deem

3 | necessary at the time of the hearing on this motion. The grounds for the motion are based upon

148678

the fact that a number of the defendants are representing themselves and have little or no

understanding of civil procedure and practice.

Dated: June 1, 2017

FIDELITY NATIONAL LAW GROUP

so
HOWARD P. BRODY, Esq.
Attorney for Plaintiff
COMMONWEALTH LAND TITLE
INSURANCE COMPANY

|PROOF OF SERVICE

STATE OF CALIFORNIA, COUNTY OF LOS ANGELES

Tam employed in the County of Los Angeles, State of California. | am over the age of

eighteen years and not a party to the within entitled action; my business address is 915 Wilshire
Blvd.. Suite 2100, Los Angeles, California 90017.

U]

mailed with postage thereon fully prepaid from Los Angeles, California. | am readily familiar

with-the firm's pra
with the U.S. Postal Service on the
‘on motion of party served, servi

On June 2, 2017, 1 served the foregoing document(s) described as:

PLAINTIVF COMMONWEALTH LAND TITLE INSURANCE COMPANY'S MOTION
IN LIMINE NO. 3 TO PRECLUDE ALL PARTIES FROM PRECONDITIONING THE
JURY DURING VOIR DIRE; MEMORANDUM OF POINTS AND AUTHORITIES;
DECLARATION OF HOWARD P. BRODY IN SUPPORT THEREOF

on the interested parties in said action:

[X] By placing the original and/or a true copy thereof enclosed in a sealed envelope

sed as follows:

SEE ATTACHED SERVICE LIST

(BY MAIL) 1 deposited such envelope in an internal collection basket. The envelope was

¢ of collection and processing correspondence for mailing. It is deposited

s presumed invalid if'a postal cancellation date or postage

meter date is more than one day afier date of deposit for mailing in affidavit.

C]

offices of the addres:

{X]

(GOLDEN STATE

by GSO (GOLDEN STATE OVERNIGHT) with deli
the person on who it is to be served, at the office addr
document filed in the cause and served on the party mak
residence.

[x]
that the foregoing is true and correct.

(BY PERSONAL SERVICE) | caused such envelope to be delivered by hand to the
e.

(BY GSO OVERNIGHT) I delivered to an authorized driver authorized by GSO
ERNIGHT) to receive documents, in an envelope or package designated

en by that person on al
¢; of at that party’s place of

{TLE} I faxed such document trom Los Angeles, California to the facsimile
The i simile machine number
ported as comple nd without error and the transmission report
msmitting facsimile machine.

(STATE) I declare under the penalty of perjury under the laws of the State of California,

Executed on June 2, 2017, at Los Angeles,

eer

( Ging

ame day in the ordinary course of business. | am aware that

fees paid or provided for, addressed to

is 213-438-

} GRACE OVIATT

“PROOF OF SERVICEco ON DH FF WN

10

28

DOCUMENT PREPARED
‘ON RECYCLED PAPER

SERVICE LIST

Commonwealth Land Title Insurance Company v. FedEx Office and Print Services Inc., et al.
Superior Court of California, County of San Francisco

Attorney for Shirley Hwang
Morgan Lopez, Esq.

Glynn & Finley, LLP

One Walnut Creek Center

100 Pringle Avenue, Suite 500
Walnut Creek, CA 94596

Fax: (925) 945-1975

milo, \GlynnFinley.com

Attorney for Elvia Palomino
Craig J. Bassett, Esq.

25 W First Street

Morgan Hill CA 95037

cbassett@garlic.com

Attorney Pro Se
Melvin L. Emerich
B10-337
4546 El Camino Real
Los Altos, CA 94022

mlemerich@yahoo.com

In Pro Per Defendant
Morad Afraimi

912 Edgecliff Drive
Reno, NV 89523

Case No. CGC-10-503332

In Pro Per Defendant

Jay C. Shah

A03101, Rm No. 6-123
California Medical facility
P.O. Box 2000

Vacaville, CA 95696

In Pro Per Defendant
Winston Lum

25 Forest Side Ave.

San Francisco, CA 94127

In Pro Per Defendant
Kaushal Niroula
ANIS18

Mule Creek State Prison
P.O. Box 409099

Tone, CA 95640

ee

PROOF OF SERVICE