On August 10, 2018 a
Motion in Limine - Motion in Limine No. 1
was filed
involving a dispute between
Santa Anita Shoppingtown Lp,
and
Dba Urban Home Dba "Urban Home",
Urban Home Inc.,
for civil
in the District Court of Los Angeles County.
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Brian D. Huben, Cal. Bar No. 134354
Nicholas M. Gross, Cal. Bar No. 285403
Tanya M. Taylor, Cal. Bar No. 312881
BALLARD SPAHR LLP
FILED
Superloy Court of California
2029 Century Park East, Suite 800 County of Los Angeles
Los Angeles, CA 90067-3012
Telephone: 424.204.4400 OCT 17 2018
Facsimile: 424.204.4350
Sherri R. Carter, Execu) ¢ Utficer/Clerk
Attorneys for Plaintiff
SANTA ANITA SHOPPINGTOWN LP
By. "At Moses
. Ade
Soto
, Deputy
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
10 SANTA ANITA SHOPPINGTOWN LP, a ) CASE NO. BC716814
Delaware limited partnership,
11 PLAINTIFF’S NOTICE OF
Plaintiff, MOTION AND MOTION IN
12 LIMINE NO. 1 TO EXCLUDE
VS, EVIDENCE NOT PRODUCED IN
13 RESPONSE TO DISCOVERY
REQUESTS; DECLARATION OF
14 URBAN HOME, INC., a California NICHOLAS M. GROSS IN
corporation, doing business as “URBAN SUPPORT THEREOF
15 HOME”; and DOES 1 through 10, inclusive;
Action Filed: August 10, 2018
16
Defendants. Trial Date: October 29, 2018
17 FSC Date: October 22, 2018
18
TO ALL PARTIES AND THEIR COUNSEL:
19
PLEASE TAKE NOTICE THAT that on October 22, 2018 at the Final Status
20
Conference in the above-referenced matter at 8:30 a.m. or as soon thereafter as this matter may
21
be heard in Department 34 of this Court, located at 111 N. Hill St., Los Angeles, California,
22
plaintiff Santa Anita Shoppingtown LP (“Plaintiff”) will move in limine for an order to preclude
23
defendant Urban Home, Inc. dba “Urban Home” (“Defendant”) from introducing any evidence
24
that was not disclosed by it in response to Plaintiff's discovery requests (the “Motion”).
25
This Motion is made pursuant to California Evidence Code section 352 on the grounds
26
that allowing Defendant to present undisclosed evidence, testimony and/or documents at trial
27
will unfairly prejudice Plaintiff, as the discovery process is central to its ability to fully
28
DMWEST #18164514 vi
PLAINTIFF’S NOTICE OF MOTION AND MOTION JN LIMINE NO. 1 TO EXCLUDE EVIDENCE NOT
PRODUCED IN RESPONSE TO DISCOVERY REQUESTS
ORIGINAL BY FAX
Document Filed Date
October 17, 2018
Case Filing Date
August 10, 2018
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Brian D. Huben, Cal. Bar No. 134354 Nicholas M. Gross, Cal. Bar No. 285403 Tanya M. Taylor, Cal. Bar No. 312881 BALLARD SPAHR LLP FILED Superloy Court of California 2029 Century Park East, Suite 800 County of Los Angeles Los Angeles, CA 90067-3012 Telephone: 424.204.4400 OCT 17 2018 Facsimile: 424.204.4350 Sherri R. Carter, Execu) ¢ Utficer/Clerk Attorneys for Plaintiff SANTA ANITA SHOPPINGTOWN LP By. "At Moses . Ade Soto , Deputy SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES 10 SANTA ANITA SHOPPINGTOWN LP, a ) CASE NO. BC716814 Delaware limited partnership, 11 PLAINTIFF’S NOTICE OF Plaintiff, MOTION AND MOTION IN 12 LIMINE NO. 1 TO EXCLUDE VS, EVIDENCE NOT PRODUCED IN 13 RESPONSE TO DISCOVERY REQUESTS; DECLARATION OF 14 URBAN HOME, INC., a California NICHOLAS M. GROSS IN corporation, doing business as “URBAN SUPPORT THEREOF 15 HOME”; and DOES 1 through 10, inclusive; Action Filed: August 10, 2018 16 Defendants. Trial Date: October 29, 2018 17 FSC Date: October 22, 2018 18 TO ALL PARTIES AND THEIR COUNSEL: 19 PLEASE TAKE NOTICE THAT that on October 22, 2018 at the Final Status 20 Conference in the above-referenced matter at 8:30 a.m. or as soon thereafter as this matter may 21 be heard in Department 34 of this Court, located at 111 N. Hill St., Los Angeles, California, 22 plaintiff Santa Anita Shoppingtown LP (“Plaintiff”) will move in limine for an order to preclude 23 defendant Urban Home, Inc. dba “Urban Home” (“Defendant”) from introducing any evidence 24 that was not disclosed by it in response to Plaintiff's discovery requests (the “Motion”). 25 This Motion is made pursuant to California Evidence Code section 352 on the grounds 26 that allowing Defendant to present undisclosed evidence, testimony and/or documents at trial 27 will unfairly prejudice Plaintiff, as the discovery process is central to its ability to fully 28 DMWEST #18164514 vi PLAINTIFF’S NOTICE OF MOTION AND MOTION JN LIMINE NO. 1 TO EXCLUDE EVIDENCE NOT PRODUCED IN RESPONSE TO DISCOVERY REQUESTS ORIGINAL BY FAX