Motion,Ex Parte: MARIA CARRASCO VS TANIA SAROYAN

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 01/13/2022 08:01 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk




                          1   Christian S. Molnar, Esq. (SBN 177665)
                              cmolnar@molnaratabek.com
                          2   MOLNAR ATABEK LLP
                              610 Newport Ctr. Dr., Ste. 420
                          3   Newport Beach, CA 92660
                          4   Tel: (213) 394-5943
                              Fax: (213) 402-3413
                          5
                              ATTORNEYS FOR DEFENDANT AND CROSS-COMPLAINANT
                          6   TANIA SAROYAN
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                          9                  THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
                         10                  FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT
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                               MARIA CARRASCO, an individual,                              Case No.: 19STCV10285
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    MOLNAR ATABEK LLP




                                               Plaintiff,                                  [Assigned for all purposes to the Honorable
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      Attorneys at Law




                                                                                           Laura A. Seigle, Department 48]
                                       vs.
                         15                                                                DEFENDANT’S MOTION IN LIMINE
                         16    TANIA SAROYAN, an individual, and                           NO. 1
                               DOES 1 through 100 inclusive,
                         17                                                                DEFENDANT TANIA SAROYAN’S
                                               Defendant.                                  NOTICE OF MOTION AND MOTION IN
                         18                                                                LIMINE TO EXCLUDE EVIDENCE OR
                         19                                                                ARGUMENT REGARDING UNPLED
                               AND RELATED CROSS-ACTIONS                                   CLAIMS, LEGAL THEORIES, CAUSES
                         20                                                                OF ACTION, DAMAGES, OR
                                                                                           DEFENSES
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                                                                                           Date: February 7, 2022
                         22                                                                Time: 8:30 a.m.
                         23                                                                Location: Department 48

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                                     TO THE COURT, ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
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                                     PLEASE TAKE NOTICE THAT on February 7, 2022, at 8:30 a.m. or as soon thereafter
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                              as the matter may be heard in Department 48 of the above captioned Court located at 111 N.
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                              Hill Street, Los Angeles, CA 90012, Defendant and Cross-Complainant TANIA SAROYAN
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                              (“Defendant”) will and hereby does move the Court for an order in limine, precluding evidence
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                              or argument regarding unpled claims, legal theories, causes of action, damages, or defenses.
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                              Any such evidence or argument regarding such unpled matter should be excluded as per se
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                              irrelevant due to be outside the scope of the pleadings, which are the absolute limit of any action
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                              before this Court.
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                                                                                            -i-
                                DEFENDANT TANIA SAROYAN’S NOTICE OF MOTION AND MOTION IN LIMINE TO EXCLUDE
                              EVIDENCE OR ARGUMENT REGARDING UNPLED CLAIMS, LEGAL THEORIES, CAUSES OF ACTION,
                                                          DAMAGES, OR DEFENSES