On July 02, 2012 a
Motion,Ex Parte
was filed
involving a dispute between
Enriquez, Gerardo,
and
Bnsf Railway Company,
for Personal Injury Non-Motor Vehicle Unlimited
in the District Court of San Bernardino County.
Preview
e
I
a ti
3 4 ii F
J
ORIGINAL
1 LEWIS BRISBOIS BISGAARD SMITH LLr SUPERIOR oL O
C FCAIIFORNIA
ANTHONY E SONNETT SB 163182 COUN
iYOF SAN t
ERNARn
I
l 0
SAN 0
tr CIVIL DIViSiON
a
B
2 E com
asonnett@lbbslaw
TREVOR J INGOLD SB 193227 APR O 1 2014
3 Mail tingold@lbbslaw
E com
V ALAN ARSHANSKY SB 251644
4 Mail aarshansky@lbbslaw
E com ap
221 N Figueroa Street Suite 1 200
5 Los Angeles California 90012
1800
250
213
Telephone
6 Facsimile 7900
250
213
7 Attorneys for Defendant
BNSF RAILWAY COMPANY
8
9
10 SUPERIOR COURT OF THE STATE OF CALIFORNIA
11 COUNTY OF SAN BERNARDINO
12
13 GERARDO ENRIQUEZ CASENO CIVBS1200342
14 Plaintiff DEFENDANT BNSF RAILWAY
COMPANY MOTION IN LIMINE NO 5
S
15 vs TO PRECLUDE EVIDENCE RELATING
TO THE RAILCAR
16 BNSF RAILWAY COMPANY and DOES lto
20 Judge Hon David S Cohn
1 Date Apri13 2014
Defendant Time 8
3 0am
lg Dept S35
19 Filed concurrently with ProposedJ OrderJ
20 Action Filed July 2 2012
Trial Date Apri17 2014
21
22 TO PLAINTIFF AND HIS ATTORNEYS OF RECORD
23 Defendant BNSF Railway Company BNSF submits the following motion in limine for
24 an order to generally preclude any opinion or testimony from plaintiff Gerardo Enriquez
25
plaintiffl his witnesses and his retained and non
retained experts as to the condition of the
26 railcar plaintiff was working on at the time of the incident and whether the railcar should have
27 been sent to the Barstow Car Department
s Heavy Repair Facility Heavies
28
LEWIS
1
5225
7835
4815
BRISBOIS
BISGAARD DEFENDANT BNSF RAILWAY COMPANY
SMOTION IN LIMINE NO 5 TO PRECLUDE EVIDENCE
RELATING TO THE RAILCAR
AiiORNEYS Ai tAW
1
1 This Motion is based on the ground that such testimony is irrelevant and would unduly
2 prejudice BNSF
3 This motion is based upon this notice the attached Memorandum of Points and
4 Authorities the Declaration of V Alan Arshansky the pleadings records and files in this action
5 all matters of which judicial notice may be taken and any oral argument that this Court may
6 consider at the hearing on this matter
7
8 DATED if0
March 2014 ANTHONY E SONNETT
TREVOR J INGOLD
9 V ALAN ARSHANSKY
LEWIS BRISBOIS BISGAARD SMITH LI
P
10
11
12 BY
V Alari A ansky
13
r
e
Atto
COMPANY
Defendant BNSF RAILWAY
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
LEWIS
BRISBOIS 1
5225
7835
4815 2
BISGAARD DEFENDANT BNSF RAILWAY COMPANY
S MOTION IN LIMINE NO 5 TO PRECLUDE EVIDENCE
RELATING TO THE RAILCAR
AiiORNEYS Ai UW
Document Filed Date
April 01, 2014
Case Filing Date
July 02, 2012
Category
Personal Injury Non-Motor Vehicle Unlimited
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e I a ti 3 4 ii F J ORIGINAL 1 LEWIS BRISBOIS BISGAARD SMITH LLr SUPERIOR oL O C FCAIIFORNIA ANTHONY E SONNETT SB 163182 COUN iYOF SAN t ERNARn I l 0 SAN 0 tr CIVIL DIViSiON a B 2 E com asonnett@lbbslaw TREVOR J INGOLD SB 193227 APR O 1 2014 3 Mail tingold@lbbslaw E com V ALAN ARSHANSKY SB 251644 4 Mail aarshansky@lbbslaw E com ap 221 N Figueroa Street Suite 1 200 5 Los Angeles California 90012 1800 250 213 Telephone 6 Facsimile 7900 250 213 7 Attorneys for Defendant BNSF RAILWAY COMPANY 8 9 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 COUNTY OF SAN BERNARDINO 12 13 GERARDO ENRIQUEZ CASENO CIVBS1200342 14 Plaintiff DEFENDANT BNSF RAILWAY COMPANY MOTION IN LIMINE NO 5 S 15 vs TO PRECLUDE EVIDENCE RELATING TO THE RAILCAR 16 BNSF RAILWAY COMPANY and DOES lto 20 Judge Hon David S Cohn 1 Date Apri13 2014 Defendant Time 8 3 0am lg Dept S35 19 Filed concurrently with ProposedJ OrderJ 20 Action Filed July 2 2012 Trial Date Apri17 2014 21 22 TO PLAINTIFF AND HIS ATTORNEYS OF RECORD 23 Defendant BNSF Railway Company BNSF submits the following motion in limine for 24 an order to generally preclude any opinion or testimony from plaintiff Gerardo Enriquez 25 plaintiffl his witnesses and his retained and non retained experts as to the condition of the 26 railcar plaintiff was working on at the time of the incident and whether the railcar should have 27 been sent to the Barstow Car Department s Heavy Repair Facility Heavies 28 LEWIS 1 5225 7835 4815 BRISBOIS BISGAARD DEFENDANT BNSF RAILWAY COMPANY SMOTION IN LIMINE NO 5 TO PRECLUDE EVIDENCE RELATING TO THE RAILCAR AiiORNEYS Ai tAW 1 1 This Motion is based on the ground that such testimony is irrelevant and would unduly 2 prejudice BNSF 3 This motion is based upon this notice the attached Memorandum of Points and 4 Authorities the Declaration of V Alan Arshansky the pleadings records and files in this action 5 all matters of which judicial notice may be taken and any oral argument that this Court may 6 consider at the hearing on this matter 7 8 DATED if0 March 2014 ANTHONY E SONNETT TREVOR J INGOLD 9 V ALAN ARSHANSKY LEWIS BRISBOIS BISGAARD SMITH LI P 10 11 12 BY V Alari A ansky 13 r e Atto COMPANY Defendant BNSF RAILWAY 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 LEWIS BRISBOIS 1 5225 7835 4815 2 BISGAARD DEFENDANT BNSF RAILWAY COMPANY S MOTION IN LIMINE NO 5 TO PRECLUDE EVIDENCE RELATING TO THE RAILCAR AiiORNEYS Ai UW