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 08:10 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,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
Ll.P
ELLROD, RAMIREZ, TRESTER
12 Plaintiff, DEFENDANT TARGET
MANNINo& KAss
CORPORATION’S MOTION IN LIMINE
13 v. #7 TO MENTION OF TARGET’S POST-
ACCIDENT PHOTOGRAPHS
- - - - A ~ . At W
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 exclude any and all questioning, testimony, argument, and/or evidence
24 concerning the post-accident photographs allegedly taken by security officer Torres; and
25 2. That all parties and their counsel direct persons under their control, including all of
26 counsel's associates, and witnesses, and persons associated with the respective parties and their
27 counsel, comply with the above referenced order, in all proceedings before the jury in this action,
28 under penalty of contempt of Court for any violation of this order.
4889-4209-1521.1
DEFENDANT TARGET CORPORATION’S MOTION IN LIMINE #7
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
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Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 10/27/2021 08:10 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,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 Ll.P ELLROD, RAMIREZ, TRESTER 12 Plaintiff, DEFENDANT TARGET MANNINo& KAss CORPORATION’S MOTION IN LIMINE 13 v. #7 TO MENTION OF TARGET’S POST- ACCIDENT PHOTOGRAPHS - - - - A ~ . At W 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 exclude any and all questioning, testimony, argument, and/or evidence 24 concerning the post-accident photographs allegedly taken by security officer Torres; and 25 2. That all parties and their counsel direct persons under their control, including all of 26 counsel's associates, and witnesses, and persons associated with the respective parties and their 27 counsel, comply with the above referenced order, in all proceedings before the jury in this action, 28 under penalty of contempt of Court for any violation of this order. 4889-4209-1521.1 DEFENDANT TARGET CORPORATION’S MOTION IN LIMINE #7