On February 19, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Ycaza Richard,
and
Target Corporation,
Zamora An Individual Priscilla,
for Premise Liability (e.g., dangerous conditions of property, slip/trip and fall, dog attack, etc.) (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 10/27/2021 08:02 PM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Guzman,Deputy Clerk
1 Eugene J. Egan, Esq. (State Bar No. 130108)
eje@manningllp.com
2 Joshua K. Babataher (State Bar No. 311367)
jkb@manningllp.com
3 MANNING & KASS
ELLROD, RAMIREZ, TRESTER LLP
4 801 S. Figueroa St, 15th Floor
Los Angeles, California 90017-3012
5 Telephone: (213) 624-6900
Facsimile: (213) 624-6999
6
Attorneys for Defendant, TARGET
7 CORPORATION
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF LOS ANGELES, CENTRAL DISTRICT
10
11 RICHARD YCAZA, Case No. 19STCV05779
12 Plaintiff, DEFENDANT TARGET
CORPORATION’S MOTION IN LIMINE
13 v. #3 TO BAR REFERENCE IN VOIR DIRE
TO THE AMOUNT OF DAMAGES
14 TARGET CORPORATION; PRISCILLA
ZAMORA, an individual; and DOES 1 to 50,
15 inclusive, Filed Concurrently with Declaration of
____________; Combined Proposed Order
16 Defendants.
Complaint Filed: 02/19/2019
17 FSC Date: 11/18/2021
Trial Date: 12/02/2021
18
19
20 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
21 Defendant TARGET CORPORATION (“Target”), before trial and the selection of the
22 jury in this action, moves this Court in limine for the following orders:
23 1. To preclude all counsel from mentioning or conveying during voir dire, whether
24 directly or indirectly, any actual or potential dollar amount of damages which plaintiff seeks, or
25 could or should be awarded in this case or in any hypothetical case; and
26 2. That all parties and their counsel direct persons under their control, including all of
27 counsel's associates, and witnesses, and persons associated with the respective parties and their
28 counsel, comply with the above referenced order, in all proceedings before the jury in this action,
4892-9028-4033.1
DEFENDANT TARGET CORPORATION’S MOTION IN LIMINE #3
Document Filed Date
October 27, 2021
Case Filing Date
February 19, 2019
Category
Premise Liability (e.g., dangerous conditions of property, slip/trip and fall, dog attack, etc.) (General Jurisdiction)
Status
Request for Dismissal - Before Trial not following ADR or more than 60 days since ADR 10/04/2021
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 10/27/2021 08:02 PM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Guzman,Deputy Clerk 1 Eugene J. Egan, Esq. (State Bar No. 130108) eje@manningllp.com 2 Joshua K. Babataher (State Bar No. 311367) jkb@manningllp.com 3 MANNING & KASS ELLROD, RAMIREZ, TRESTER LLP 4 801 S. Figueroa St, 15th Floor Los Angeles, California 90017-3012 5 Telephone: (213) 624-6900 Facsimile: (213) 624-6999 6 Attorneys for Defendant, TARGET 7 CORPORATION 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF LOS ANGELES, CENTRAL DISTRICT 10 11 RICHARD YCAZA, Case No. 19STCV05779 12 Plaintiff, DEFENDANT TARGET CORPORATION’S MOTION IN LIMINE 13 v. #3 TO BAR REFERENCE IN VOIR DIRE TO THE AMOUNT OF DAMAGES 14 TARGET CORPORATION; PRISCILLA ZAMORA, an individual; and DOES 1 to 50, 15 inclusive, Filed Concurrently with Declaration of ____________; Combined Proposed Order 16 Defendants. Complaint Filed: 02/19/2019 17 FSC Date: 11/18/2021 Trial Date: 12/02/2021 18 19 20 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 21 Defendant TARGET CORPORATION (“Target”), before trial and the selection of the 22 jury in this action, moves this Court in limine for the following orders: 23 1. To preclude all counsel from mentioning or conveying during voir dire, whether 24 directly or indirectly, any actual or potential dollar amount of damages which plaintiff seeks, or 25 could or should be awarded in this case or in any hypothetical case; and 26 2. That all parties and their counsel direct persons under their control, including all of 27 counsel's associates, and witnesses, and persons associated with the respective parties and their 28 counsel, comply with the above referenced order, in all proceedings before the jury in this action, 4892-9028-4033.1 DEFENDANT TARGET CORPORATION’S MOTION IN LIMINE #3