Motion-Secondary: FROYLAN PINEDA ROJAS, ET AL. VS NISSAN NORTH AMERICA, INC., A CALIFORNIA CORPORATION

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 07/22/2021 09:12 AM Sherri R. Carter, Executive Officer/Clerk of Court, by W. Moore,Deputy Clerk




               1      KLEIN THOMAS & LEE
                      Anthony S. Thomas (SBN 149284)
               2      1100 W. Town & Country Road
                      Suite 1250
               3      Orange, CA 92868
                      Tel: (310) 424-4009
               4      Email: Tony.thomas@kleinthomaslaw.com
               5      Attorney for Defendant Nissan North America, Inc.
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               8                                               SUPERIOR COURT OF CALIFORNIA
               9                                                       COUNTY OF LOS ANGELES

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             11       FROYLAN PINEDA ROJAS aka                                                 )      CASE NO.: 19STCV26034
                      FROYLAN PINEDA and                                                       )
             12       JOSEFINA CATALAN MORALES,
                                                                                               )      Assigned to: Hon. David Sotelo
             13                                         Plaintiffs,                            )      Department: 40
                                                                                               )
             14                  vs.                                                           )      NISSAN NORTH AMERICA, INC.’S
                                                                                               )      OPPOSITION TO PLAINTIFF’S
             15       NISSAN NORTH AMERICA, INC.,                                            a
                      California Corporation, and DOES                                       1 )      MOTION IN LIMINE NO. 1
             16       through 10, inclusive,                                                   )
                                                                                               )
             17                                         Defendants.                            )      Action Filed: July 25, 2019
                                                                                               )      Trial:        August 24, 2021
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             19                  TO ALL PARTIES AND THEIR ATTORNEY OF RECORD:
             20                  Nissan North America, Inc. (NNA) hereby opposes plaintiff’s Motion in Limine No.
             21       1 because this is a generic motion has no supporting evidence with respect to what
             22       “information, argument or facts” plaintiff seeks to exclude as prejudicial, and therefore,
             23       NNA wants to avoid a blanket order based upon a nebulous request.
             24       I.         LEGAL ARGUMENT
             25                  Motions in limine are normally filed immediately prior to trial to prevent the
             26       admission of, or questions regarding, prejudicial evidence. The purpose is to avoid the
             27       futile attempt of trying to “un-ring the bell” once the question is asked. Such a motion to
             28       exclude must be based on grounds that would be sufficient to object or move to strike the



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                             NISSAN NORTH AMERICA, INC.’S OPPOSITION TO PLAINTIFF’S MOTION IN LIMINE NO. 1