Motion,Ex Parte: LORI BUSH -V- ST BERNADINE MEDICAL CENTER Print

• 
• 
• 
• 

						
                                
Preview
                                LAW OFFICES 0F MICHAEL J. LIBMAN, APC
     MICHAEL J. LIBMAN (SBN 222353)
     ZHANNA SANAMYAN (SBN 337133)
     18321 Ventura Boulevard, Suite 700
     Tarzana, California 91 356
     Telephone: (81 8) 995-7300
     Facsimile: (866) 644-6764
     mjl@libmanlaw.com

     GARY BERKOVICH (SBN 192731)                                                           Fl L E           D
     A PROFESSIONAL CORPORATION                                                            ggURT
                                                                                StéPoEuRrngR             OF CALIFORNm
     14900 Ventura Boulevard, Suite 220                                            SAN BEWAfififvaffitw
                                                                                               “
     Sherman Oaks, California 91403
     Telephone: (818) 465-9505
                                                                                         FEB        I   4 2022
     Facsimile: (818) 358—2829


10   Attorneys for   Plaintiff,     LORI BUSH

ll


12
                           SUPERIOR COURT OF THE STATE OF CALIFORNIA
13
         FOR THE COUNTY OF SAN BERNARDINO — SAN BERNARDINO DISTRICT
l4
     LORI BUSH, an         individual.                    )       CASE NUMBER: CIVDSI613161
15
                            _   _
                                                          )       Hon. John M. Pacheco
                         Plamt‘ff’
l6                                                                Dept: s31
                                                          g
l7          vs.
                                                          )       PLAINTIFF’S OPPOSITION T0
18
                                                          )       DEFENDANT TOTAL PROFESSIONAL
                                                          )       NETWORK, INC’S MOTION IN LIMINE
l9
     ST-,BERNA_RDINE            MEDICAL CENTER,       a
                                                          )       N0. 8 PRECLUDING PLAINTIFF’S USE
     busmess    entlty   form unknown;   DIGNITY          )       OF IRRELEVANT AND PREJUDICIAL
2O   HEALTH,      a California Corporation; and
                                                          )       EVIDENCE OR ARGUMENT AT TRIAL
     DOES   1   through 200, inclusive
                                                          )       KNOWN AS THE “REPTILE THEORY”
21
                                                          )
                         DefendantS-
22                                                        )       Trial Date:   February       7,   2021
                                                          )       Time:         10:00 A.M.
23
                                                          )       Dept.         831
                                                          )
24
                                                          )

25

26

27
            TO THE HONORABLE COURT AND DEFENDANTS BY AND THROUGH

28
     THEIR COUNSEL OF RECORD:
            Plaintiff     LORI BUSH       (“Plaintiff”)   hereby opposes Defendant Total                    Professional

                                                              1

     PLAINTIFF’S OPPOSITION TO DEFENDANT TOTAL PROFESSIONAL NETWORK, INC’S MOTION IN LIMINE NO. 8 PRECLUDING
       PLAINTIFF’S USE OF IRRELEVANT AND PREJUDICIAL EVIDENCE OR ARGUMENT AT TRIAL KNOWN AS THE “REPTILE
                                                      THEORY”
     Network, Inc’s (“Defendant”)                MOTION IN LIMINE                  NO.   7   PRECLUDING PLAINTIFF’S
     USE OF IRRELEVANT AND PREJUDICIAL EVIDENCE 0R ARGUMENT AT TRIAL
     KNOWN AS THE “REPTILE THEORY”
               This opposition          is   based on the grounds that         this   motion does not seek to exclude a

     particular piece        of evidence as        is   required in Kelly     v.   New       West Federal Savings (1996) 49

     Cal.App.4th 659, 671. For that reason alone this motion must be denied.

                Further, this      is   an improper attempt to impose a “gag order” on Plaintiff‘s counsel and

     dictate the    way      in   which      plaintiff should try her      own     case and an attempt to influence this

     honorable court.        As   such, this motion       must be denied.
10
               This opposition shall be based on the attached               memorandum of points and            authorities,
ll
     all   papers currently on file           in this case,   and any such filrther evidence or argument the Court
12
     may    allow   at the   hearing on this motion.
13


l4


l5


l6

l7
     DATED:      January 25, 2022




                                                              By:
                                                                        W MM
                                                              LAW OFFICE 0F MICHAEL J. LIBMAN, APC

                                                                                         fl            [E-Signature]




18                                                                  Michael   J.   Libman
                                                                    Attorneys for Plaintiff
l9                                                                  LORI BUSH

20

21

22


23

24

25

26

27

28




                                                                    2
     PLAINTIFF’S OPPOSITION TO DEFENDANT TOTAL PROFESSIONAL NETWORK, INC’S                    MOTION IN LIMINE NO. 8 PRECLUDING
        PLAINTIFF’S USE OF IRRELEVANT AND PREJUDICIAL EVIDENCE OR ARGUMENT                    AT TRIAL KNOWN AS THE “REPTILE
                                                                 THEORY”