On November 29, 2017 a
Request,Application
was filed
involving a dispute between
Conrado, Diego,
and
Cls Landscaping Management, Inc,
Espinoza Gonzalez, Jose Juan,
for Personal Injury Motor Vehicle Unlimited
in the District Court of San Bernardino County.
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Christopher B. Dolan (SBN 165358)
Aimee E. Kirby (SBN 216909)
Cristina Garcia (SBN 308161)
DOLAN LAW FIRM, PC
1438 Market Street
San Francisco, California 94102
Telephone: (415) 42 1-2800
Facsimile: (415)421-2830
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DIEGO CONRADO
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
BY FAX
DIEGO CONRADO, an individual, Case N0. CIVDS 1 723453
Plaintiff,
REQUEST FOR JUDICIAL NOTICE OF
V. EXHIBIT “G” SUBMITTED IN SUPPORT OF
PLAINTIFF’S MOTION IN LIMINE
CLS LANDSCAPING MANAGEMENT ’ NO. 20: TO EXCLUDE EVIDENCE AND
INC, JOSE JUAN ESPINOZA ARGUMENTS OF VEHICLE OWNERSHIP
GONZALEZ, and DOES 1 to 50,
Defendants.
[Filed concurrently with Plaintiff’ s Motion in
NNNNNNNNNAAAJAAAAAA
Limine No. 20]
OONOUU‘ILOONAocomVO‘JUI-boomA
Trial Date: October 18, 2021
Time: 10:00 am.
Dept: S30
TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD HEREIN :
Plaintiff respectfully requests that the Court take Judicial Notice 0f the Department of Motor
Vehicle’s Transfer of Title webpages attached to Plaintiff’s Motion in Limine No. 20 as Exhibit “G”.
The requests and the authorities in support, thereof, are set forth below.
REQIUEST FOR JUDICIAL NOTICE
—A
MEMORANDUM OF POINTS AND AUTHORITIES
I. INTRODUCTION/STATEMENT OF FACTS
This personal injury action arises from a motor vehicle collision that occurred on January 4,
2016, in Chino, California. Plaintiff Diego Conrado (“Plaintiff” 0r “Mr. Conrado”) was a passenger in
the 1998 Honda Civic involved in the collision and suffered catastrophic injuries. Plaintiff filed a
OLOOOVGCNAOJN
complaint on November 29, 2017, for motor vehicle negligence, seeking economic and non-economic
damages for his injuries sustained as a result of the collision.
Plaintiff requests Judicial Notice 0f the Department of Motor Vehicle’s Transfer of Title
webpages attached as Exhibit “G” t0 Plaintiff’s Motion in Limine No. 20: To Exclude Evidence and
Arguments of Vehicle Ownership. Plaintiff has attached Exhibit “G” herein for the Court’s convenience.
II. AUTHORITY
The California Evidence Code has provisions for mandatory judicial notice and permissive
judicial notice. According t0 the rules for Mandatory Judicial Notice:
Judicial notice shall be taken 0f the following:
(a) The decisional, constitutional, and public statutory law 0f this state and 0f the
United States and the provisions 0f any charter described in Section 3, 4, or 5 of
Article XI of the California Constitution.
(b) Any matter made a subject of judicial notice by Section 11343.6, 11344.6, or
18576 of the Government Code or by Section 1507 of Title 44 0f the United States
Code.
(c) Rules 0f professional conduct for members of the bar adopted pursuant t0 Section
6076 0f the Business and Professions Code and rules of practice and procedure for the
courts of this state adopted by the Judicial Council.
(d) Rules of pleading, practice, and procedure prescribed by the United States
Supreme Court, such as the Rules of the United States Supreme Court, the Federal
Rules 0f Civil Procedure, the Federal Rules 0f Criminal Procedure, the Admiralty
Rules, the Rules of the Court of Claims, the Rules of the Customs Court, and the
General Orders and Forms in Bankruptcy.
(e) The true signification of all English words and phrases and of all legal expressions.
(f) Facts and propositions 0f generalized knowledge that are so universally known that
they cannot reasonably be the subject 0f dispute.
(Evid. Code, § 451)
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REQUEST FOR JUDICIAL NOTICE
Document Filed Date
October 06, 2021
Case Filing Date
November 29, 2017
Category
Personal Injury Motor Vehicle Unlimited
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Christopher B. Dolan (SBN 165358) Aimee E. Kirby (SBN 216909) Cristina Garcia (SBN 308161) DOLAN LAW FIRM, PC 1438 Market Street San Francisco, California 94102 Telephone: (415) 42 1-2800 Facsimile: (415)421-2830 ‘ OLOOOVOCB-waA BY ‘7? ’L' I / -vzdfigx‘fi/iC/{ifazé < {/sz s L—PHANIE Attorneys for Plaintiff y CARR bi? r—‘uw DIEGO CONRADO SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO BY FAX DIEGO CONRADO, an individual, Case N0. CIVDS 1 723453 Plaintiff, REQUEST FOR JUDICIAL NOTICE OF V. EXHIBIT “G” SUBMITTED IN SUPPORT OF PLAINTIFF’S MOTION IN LIMINE CLS LANDSCAPING MANAGEMENT ’ NO. 20: TO EXCLUDE EVIDENCE AND INC, JOSE JUAN ESPINOZA ARGUMENTS OF VEHICLE OWNERSHIP GONZALEZ, and DOES 1 to 50, Defendants. [Filed concurrently with Plaintiff’ s Motion in NNNNNNNNNAAAJAAAAAA Limine No. 20] OONOUU‘ILOONAocomVO‘JUI-boomA Trial Date: October 18, 2021 Time: 10:00 am. Dept: S30 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD HEREIN : Plaintiff respectfully requests that the Court take Judicial Notice 0f the Department of Motor Vehicle’s Transfer of Title webpages attached to Plaintiff’s Motion in Limine No. 20 as Exhibit “G”. The requests and the authorities in support, thereof, are set forth below. REQIUEST FOR JUDICIAL NOTICE —A MEMORANDUM OF POINTS AND AUTHORITIES I. INTRODUCTION/STATEMENT OF FACTS This personal injury action arises from a motor vehicle collision that occurred on January 4, 2016, in Chino, California. Plaintiff Diego Conrado (“Plaintiff” 0r “Mr. Conrado”) was a passenger in the 1998 Honda Civic involved in the collision and suffered catastrophic injuries. Plaintiff filed a OLOOOVGCNAOJN complaint on November 29, 2017, for motor vehicle negligence, seeking economic and non-economic damages for his injuries sustained as a result of the collision. Plaintiff requests Judicial Notice 0f the Department of Motor Vehicle’s Transfer of Title webpages attached as Exhibit “G” t0 Plaintiff’s Motion in Limine No. 20: To Exclude Evidence and Arguments of Vehicle Ownership. Plaintiff has attached Exhibit “G” herein for the Court’s convenience. II. AUTHORITY The California Evidence Code has provisions for mandatory judicial notice and permissive judicial notice. According t0 the rules for Mandatory Judicial Notice: Judicial notice shall be taken 0f the following: (a) The decisional, constitutional, and public statutory law 0f this state and 0f the United States and the provisions 0f any charter described in Section 3, 4, or 5 of Article XI of the California Constitution. (b) Any matter made a subject of judicial notice by Section 11343.6, 11344.6, or 18576 of the Government Code or by Section 1507 of Title 44 0f the United States Code. (c) Rules 0f professional conduct for members of the bar adopted pursuant t0 Section 6076 0f the Business and Professions Code and rules of practice and procedure for the courts of this state adopted by the Judicial Council. (d) Rules of pleading, practice, and procedure prescribed by the United States Supreme Court, such as the Rules of the United States Supreme Court, the Federal Rules 0f Civil Procedure, the Federal Rules 0f Criminal Procedure, the Admiralty Rules, the Rules of the Court of Claims, the Rules of the Customs Court, and the General Orders and Forms in Bankruptcy. (e) The true signification of all English words and phrases and of all legal expressions. (f) Facts and propositions 0f generalized knowledge that are so universally known that they cannot reasonably be the subject 0f dispute. (Evid. Code, § 451) /// /// 2 REQUEST FOR JUDICIAL NOTICE