Motion-Secondary: ALFREDO HERRERA VS HILBERT PROPERTY MANAGEMENT, AN UNKNOWN BUSINESS ENTITY

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 09/28/2021 11:40 AM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Bolden,Deputy Clerk




                        1     Kaveh S. Elihu, Esq. (SBN 268249)
                              Daniel J. Friedman, Esq. (SBN 289670)
                        2     EMPLOYEE JUSTICE LEGAL GROUP
                              3055 Wilshire Boulevard, Suite 1120
                        3     Los Angeles, California 90010
                              Telephone: (213) 382-2222
                        4     Facsimile: (213) 382-2230
                              Attorneys for Plaintiff
                        5     ALFREDO HERRERA
                        6
                                                           SUPERIOR COURT OF THE STATE OF CALIFORNIA
                        7
                                                                        FOR THE COUNTY OF LOS ANGELES
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                        9     ALFREDO HERRERA, an individual,                                                   CASE NO.: 19STCV27252
                      10                                                                                        Assigned for all Purposes to the Hon.
                                                                          Plaintiff,
                                           v.                                                                   Monica Bachner in dept. 71
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                      12      HILBERT PROPERTY MANAGEMENT, an                                                   PLAINTIFF’S OPPOSITION TO
                              unknown business entity; and DOES 1 through                                       DEFENDANT HILBERT PROPERTY
                      13      20, inclusive,                                                                    MANAGEMENT’S MOTION IN
                                                                                                                LIMINE NO. 3 TO PRECLUDE LAY
                      14                                                                                        AND EXPERT TESTIMONY
                                                                           Defendants
                                                                                                                REGARDING PLAINTIFF'S CLAIMED
                      15                                                                                        DAMAGES FOR PAST AND FUTURE
                                                                                                                WAGES AND BENEFITS;
                      16
                                                                                                                Action Filed: August 02, 2019
                      17                                                                                        Trial Date: October 18, 2021
                      18                                                                                        Final Status Conference:
                                                                                                                Date: October 8, 2021
                      19                                                                                        Time:9:00 a.m.
                                                                                                                Dept: 71
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                      21      TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD:
                                   PLEASE TAKE NOTICE that Plaintiff Alfredo Herrera hereby opposes the motion in
                      22

                      23      limine #3 by Defendant Hilbert Property Management (“HPM”) for an order precluding lay and

                      24      expert testimony regarding Plaintiff’s claimed damages for past and future wages and benefits, and

                      25      submits the following memorandum of points and authorities in support of his position.
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                               PLAINTIFF OPLAINTIFF’S OPPOSITION TO DEFENDANT HILBERT PROPERTY MANAGEMENT’S
                                   MOTION IN LIMINE NO. 3 TO PRECLUDE LAY AND EXPERT TESTIMONY REGARDING
                                PLAINTIFF'S CLAIMED DAMAGES FOR PAST AND FUTURE WAGES AND BENEFITSRIEDMAN