On March 02, 2015 a
Motion,Ex Parte
was filed
involving a dispute between
Rigoli, Brianne,
and
C.R. England, Inc. A Utah Corporation,
England Global Logistics Usa, Inc. A Utah Corporation,
Torres, Lorena,
Rigoli, Brianne,
for Wrongful Termination
in the District Court of San Bernardino County.
Preview
1 Jeffrey A Rager Esq SBN 185216 F 1 L E D
7ames Y Yoon Esq SBN 289906 SUPERIOR COURT OF CALIFORNIA
COUN7Y OF SAN BERNARDINO
2 THE RAGER LAW FIRM SAN BERNARDIN OIS7RICT
970 West 190 Street Suite 340
3 Torrance California 90502 MAR 2 8 2018
Telephone 310 527 6994
4 Email jeffcr ragerlawoffices com
ames i ragerlawoffices com
DAN El ERLEIN DEPUTY
5
Melanie Savarese Esq SBN 216950
6 Savarese Law Firm
37 W Sierra Madre Blvd
7 Sierra Madre CA 91024
Phone 626 355 3264
8 Facsimile 626 355 3491
Email melanie
e
savaresela rm com
9
Attorneys for Plaintiff BRIANNE RIGOLI
10
11 SUPERIOR COURT OF THE STATE OF CALIFORNIA
12 FOR THE COUNTY OF SAN BERNARDINO
13
14 BRIANNE RIGOLI CASE No CIVDS 1502545
15 Assigned to Hon Janet M Frangie Dept S29
Plaintiff
16
vs MOTION IN LIMINE NO 8 TO PRECLUDE
17 DEFENDANT S GOOD TREATMENT
TOWARD OTHER EMPLOYEES
18 C R ENGLAND INC a Utah Corporation
ENGLAND GLOBAL LOGISTICS USA INC Trial Readiness o erence
19 a Utah Corporation LORENA TORRES an D at e pr 018
individual and DOES 1 through 10 inclusive T ie 8 0 am
20 Dept S29
21 Defendants Trial April 9 2018
22
23
24
25
26
27
28
MOTION 1N LIMINE NO 8 TO PRECLUDE DEFENDANT S GOOD TREATMENT
TOWARD OTHER EMPLOYEES
1 TO DEFENDANTS AND THEIR ATTORNEYS OF RECORD
2 PLEASE TAKE NOTICE that plaintiff hereby moves this Court in Limine for an order
3 excluding evidence of instances when Defendant has not retaliated or discriminated against its other
4 employees Plaintiff expects Defendant to attempt to call other employees to testify that they were not
5 discriminated against or that they made protected complaints or engaged in other protected conduct and
6 were not retaliated against Defendant will attempt to use this type of evidence to convince the jury that
7 because they did not do it then they did not do it to Ms Rigoli This is improper
8 The evidence should be excluded pursuant to Evidence Code sections 1101 a and caselaw
9 pertaining to the private nature of employment records
10 Plaintiff further moves the Court to instruct defendants and their counsel and to require counsel
11 to advise all witnesses
12 1 Not to attenclpt to convey to the jury directly or indirectly any ofthe facts mentioned in
13 this motion without first obtaining permission ofthe Court outside the presence and hearing of the jury
14 2 Not to make any reference to the fact that this motion has been filed and
15 3 To warn and caution each ofdefendants witnesses to strictly follow the same instructions
16 This motion is based upon the supporting memorandum of points and authorities the papers and
17 pleadings on file herein and upon such further matters that may be presented at the time of the hearing
18 of said motion
19 Dated March 27 2018 THE RAG LA FIRM
20
21 By
Jeffrey A Rager
22 Melanie Savarese
Attorneys for Plai iff BRIANNE RIGOLI
23
24
25
26
27
28
MOTION 1N LIMINE NO 8 TO PRECLUDE DEFENDANT S GOOD TREATMENT
TOWARD OTHER EMPLOYEES
Document Filed Date
March 28, 2018
Case Filing Date
March 02, 2015
Category
Wrongful Termination
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1 Jeffrey A Rager Esq SBN 185216 F 1 L E D 7ames Y Yoon Esq SBN 289906 SUPERIOR COURT OF CALIFORNIA COUN7Y OF SAN BERNARDINO 2 THE RAGER LAW FIRM SAN BERNARDIN OIS7RICT 970 West 190 Street Suite 340 3 Torrance California 90502 MAR 2 8 2018 Telephone 310 527 6994 4 Email jeffcr ragerlawoffices com ames i ragerlawoffices com DAN El ERLEIN DEPUTY 5 Melanie Savarese Esq SBN 216950 6 Savarese Law Firm 37 W Sierra Madre Blvd 7 Sierra Madre CA 91024 Phone 626 355 3264 8 Facsimile 626 355 3491 Email melanie e savaresela rm com 9 Attorneys for Plaintiff BRIANNE RIGOLI 10 11 SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 FOR THE COUNTY OF SAN BERNARDINO 13 14 BRIANNE RIGOLI CASE No CIVDS 1502545 15 Assigned to Hon Janet M Frangie Dept S29 Plaintiff 16 vs MOTION IN LIMINE NO 8 TO PRECLUDE 17 DEFENDANT S GOOD TREATMENT TOWARD OTHER EMPLOYEES 18 C R ENGLAND INC a Utah Corporation ENGLAND GLOBAL LOGISTICS USA INC Trial Readiness o erence 19 a Utah Corporation LORENA TORRES an D at e pr 018 individual and DOES 1 through 10 inclusive T ie 8 0 am 20 Dept S29 21 Defendants Trial April 9 2018 22 23 24 25 26 27 28 MOTION 1N LIMINE NO 8 TO PRECLUDE DEFENDANT S GOOD TREATMENT TOWARD OTHER EMPLOYEES 1 TO DEFENDANTS AND THEIR ATTORNEYS OF RECORD 2 PLEASE TAKE NOTICE that plaintiff hereby moves this Court in Limine for an order 3 excluding evidence of instances when Defendant has not retaliated or discriminated against its other 4 employees Plaintiff expects Defendant to attempt to call other employees to testify that they were not 5 discriminated against or that they made protected complaints or engaged in other protected conduct and 6 were not retaliated against Defendant will attempt to use this type of evidence to convince the jury that 7 because they did not do it then they did not do it to Ms Rigoli This is improper 8 The evidence should be excluded pursuant to Evidence Code sections 1101 a and caselaw 9 pertaining to the private nature of employment records 10 Plaintiff further moves the Court to instruct defendants and their counsel and to require counsel 11 to advise all witnesses 12 1 Not to attenclpt to convey to the jury directly or indirectly any ofthe facts mentioned in 13 this motion without first obtaining permission ofthe Court outside the presence and hearing of the jury 14 2 Not to make any reference to the fact that this motion has been filed and 15 3 To warn and caution each ofdefendants witnesses to strictly follow the same instructions 16 This motion is based upon the supporting memorandum of points and authorities the papers and 17 pleadings on file herein and upon such further matters that may be presented at the time of the hearing 18 of said motion 19 Dated March 27 2018 THE RAG LA FIRM 20 21 By Jeffrey A Rager 22 Melanie Savarese Attorneys for Plai iff BRIANNE RIGOLI 23 24 25 26 27 28 MOTION 1N LIMINE NO 8 TO PRECLUDE DEFENDANT S GOOD TREATMENT TOWARD OTHER EMPLOYEES