On November 29, 2017 a
Motion,Ex Parte
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.
Preview
Christopher B Dolan SBN 165358
Airr e E Kirby SBN 216909
2
Cristina Garcia SBN 308161
DOLAN LAW FIRM PC
3
1438 Market Street t A
s
4 San Francisco California 94102 nv
Telephone 415 421 2800
5 Facsimile 415 421 2830 Q
6
s
GerardFriend SBN 101718 r
4 d y
7 The Law Office of Gerard Friend
1348 S Flower St
Los Angeles CA 90015
Telephone 213 689 8900
9
10 Attorneys for Plaintiff
DIEGO CONRADO
11
12 SUPERIOR COURT OF THE STATE OF CALIFORNIA
13 COUNTY OF SAN BERNARDINO
14
DIEGO CONRADO an individual Case No CIVDS 1723453
15
Plaintiff
PLAINTIFF S MOTION IN LIMINE NO 14
16
v TO EXCLUDE EVIDENCE AND OR
17 ARGUMENTS THAT PLAINTIFF FAILED TO
CLS LANDSCAPING MANAGEMENT CALL ALL TREATING PHYSICIANS
8 INC JOSE JUAN ESPINOZA
GONZALEZ and DOES 1 to 50 Trial Date March 9 2020
9
Defendants Time 10 00 a m
Dept S30
20
21 l
22
TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD HEREIN
23
PLEASE TAKE NOTICE that on March 5 2020 at 8 30 a m in Dept S30 of the above
24 will move this Court
entitled Cotut Plaintiff DIEGO CONRADO Plaintiff or Mr CONRADO
25
for an issuance of the following orders in limine
26 1 An order excluding any and all evidence testimony references insinuations suggestions
27 accusations argument or any mention of any kind that Plaintiff failed to call all his treatin
2g physicians
1
PLAINTIFF S MOTION IN LIMINE NO 14
1 2 An order requiring the attorneys far all parties to instruct their witnesses of the court
2 exclusionary order on this motion and
3 3 An order requiring the attorney for Defendant prior to making any references comments or
4 assertions concerning such matters to approach the bench and make an offer of proofto the
5 court so that the court prior to any presentation of the above referenced evidence to the jury
6 can rnake a preliminary determination of the relevancy and admissibility thereof
This motion is based upon Evidence Code sections 350 and 352 The motion is further base
7
upon the supporting Memorandum of Points and Authorities the pleadings and papers on file in thi
action and upon such argument and evidence as may be presented prior to or at the hearing of thi
9
matter
10
11
DATED February 26 2020 DC LAN LAW FIRM PC
12
13 gy c i
Chnstopher B Dolan Esq
14 Aimee E Kirby Esq
Cristina Garcia Esq
15 Attorneys for Plaintiff
DIEGO CONRADO
16
17
18
19
20
21
22
23
24
25
26
27
28
2
PLAINTIFF S MOTION IN LIMINE NO 14
Document Filed Date
February 26, 2020
Case Filing Date
November 29, 2017
Category
Personal Injury Motor Vehicle Unlimited
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Christopher B Dolan SBN 165358 Airr e E Kirby SBN 216909 2 Cristina Garcia SBN 308161 DOLAN LAW FIRM PC 3 1438 Market Street t A s 4 San Francisco California 94102 nv Telephone 415 421 2800 5 Facsimile 415 421 2830 Q 6 s GerardFriend SBN 101718 r 4 d y 7 The Law Office of Gerard Friend 1348 S Flower St Los Angeles CA 90015 Telephone 213 689 8900 9 10 Attorneys for Plaintiff DIEGO CONRADO 11 12 SUPERIOR COURT OF THE STATE OF CALIFORNIA 13 COUNTY OF SAN BERNARDINO 14 DIEGO CONRADO an individual Case No CIVDS 1723453 15 Plaintiff PLAINTIFF S MOTION IN LIMINE NO 14 16 v TO EXCLUDE EVIDENCE AND OR 17 ARGUMENTS THAT PLAINTIFF FAILED TO CLS LANDSCAPING MANAGEMENT CALL ALL TREATING PHYSICIANS 8 INC JOSE JUAN ESPINOZA GONZALEZ and DOES 1 to 50 Trial Date March 9 2020 9 Defendants Time 10 00 a m Dept S30 20 21 l 22 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD HEREIN 23 PLEASE TAKE NOTICE that on March 5 2020 at 8 30 a m in Dept S30 of the above 24 will move this Court entitled Cotut Plaintiff DIEGO CONRADO Plaintiff or Mr CONRADO 25 for an issuance of the following orders in limine 26 1 An order excluding any and all evidence testimony references insinuations suggestions 27 accusations argument or any mention of any kind that Plaintiff failed to call all his treatin 2g physicians 1 PLAINTIFF S MOTION IN LIMINE NO 14 1 2 An order requiring the attorneys far all parties to instruct their witnesses of the court 2 exclusionary order on this motion and 3 3 An order requiring the attorney for Defendant prior to making any references comments or 4 assertions concerning such matters to approach the bench and make an offer of proofto the 5 court so that the court prior to any presentation of the above referenced evidence to the jury 6 can rnake a preliminary determination of the relevancy and admissibility thereof This motion is based upon Evidence Code sections 350 and 352 The motion is further base 7 upon the supporting Memorandum of Points and Authorities the pleadings and papers on file in thi action and upon such argument and evidence as may be presented prior to or at the hearing of thi 9 matter 10 11 DATED February 26 2020 DC LAN LAW FIRM PC 12 13 gy c i Chnstopher B Dolan Esq 14 Aimee E Kirby Esq Cristina Garcia Esq 15 Attorneys for Plaintiff DIEGO CONRADO 16 17 18 19 20 21 22 23 24 25 26 27 28 2 PLAINTIFF S MOTION IN LIMINE NO 14