Motion,Ex Parte: FELIKS ZIBELBERG VS SCOTT LEE BERK

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 11/03/2022 04:33 PM Sherri R. Carter, Executive Officer/Clerk of Court, by A. Trinh,Deputy Clerk


                    Rosie Barmakszian, Esq. (SBN: 263177)
                  1 BARM LAW
                    2600 W. Olive Ave., Suite #500
                  2 Burbank, CA 91505
                    P: (818) 333-5353
                  3 F: (818) 478-3080
                    E: barmlaw2009@gmail.com
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                    Attorneys for Plaintiff, FELIKS ZIBELBERG
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                  6                                  SUPERIOR COURT OF THE STATE OF CALIFORNIA
                  7                FOR THE COUNTY OF LOS ANGELES – SPRING STREET COURTHOUSE
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                  9 FELIKS ZIBELBERG,                                                                 )     Case No.: 20STCV41701
                                                                                                      )
                10                                     Plaintiff,                                     )   PLAINTIFF’S MOTION IN LIMINE TO
                                                                                                      )   EXCLUDE ALL EVIDENCE OF NON-
                11                 vs.                                                                )   CALLED WITNESSES [MIL 5 of 6];
                                                                                                      )   DECLARATION OF ROSIE
                12                                                                                    )   BARMAKSZIAN; [PROPOSED] ORDER
                                                                                                      )
                13 SCOTT LEE BERK; and DOES 1-10,                                                     )   Honorable: Audra Mori
                                                                                                          FSC Date: November 30, 2022
                                                                                                      )   Time: 10:00 a.m.
                14                                   Defendants.                                      )   Trial Date: December 14, 2022
                                                                                                      )   Department: “31”
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                                   TO THIS HONORABLE COURT, DEFENDANTS, AND TO THEIR ATTORNEYS
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                        OF RECORD:
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                                   Plaintiff, FELIKS ZIBELBERG (hereinafter “PLAINTIFF”), moves this Court in limine for
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                        an order excluding all evidence, references to evidence, testimony or argument relating
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                        PLAINTIFF’s decision not to call certain witnesses to testify at trial.
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                                   This motion is based on the grounds that the evidence is irrelevant, immaterial, confusing,
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                        and will create a substantial danger of undue prejudice to PLAINTIFF. This motion is further based
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                        upon the supporting Memorandum of Points and Authorities, the pleadings and papers on file in this
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                        action, and upon such argument and evidence as may be presented prior to or at the hearing of this
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                        matter.
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                        PLAINTIFF’S MOTION IN LIMINE TO EXCLUDE ALL EVIDENCE OF NON-CALLED WITNESSES [MIL 5 of 6]