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
Aimee E Kirby SBN 216909
2
Cristina Garcia SBN 308161
DOLAN LAW FIRM PC
3
1438 Market Street
v
4 San Francisco California 94102 cc tc
s r
Telephone 415 421 2800
5 Facsimile 415 421 2830
6 y
Gerard Friend SBN 101718 3Y s
7 The Law Office of Gerard Friend 7 rr 3 r
1348 S Flower St
Los Angeles CA 90015
Tel 213 689 8900
9
10 Attorneys for Plaintiff
DIEGO CONRADO
11
12 SUPERIOR COURT OF THF STATE OF CALIFORNIA
13 COUNTY OF SAN BERNARDINO
14
DIEGO CONRADO an individual Case No CNDS1723453
15
Plaintiff
PLAINTIFF S MOTION IN LIMINE NO 17
16
v TO EXCLUDE CUMMULATIVE EXPERT
17 TESTIMONY ON THE ISSUE OF COMPLEX
CLS LANDSCAPiNG MANAGEMENT REGIONAL PAIN SYNDROME CRPS
8 1NC JOSE JUAN ESPINOZA
GONZALEZ and DOES 1 to 50 Trial Date March 9 2020
9
Defendants Time 10 00 a m
20 Dept S30
I
21
22
TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD HEREIN
23
PLEASE TAKE NOTICE that on March 5 2020 at 830 a m in Dept S30 of the
24 above entitled Court Plaintiff DIEGO CONRADO Plaintiff or Mr CONRADO will move this
25
Court for an issuance of the following orders in limine
26 1 An Complex Regional Pain Syndrome
order
limiting the hereafter CRPS diagnosis
27 damage testimony to Bounds MD who was designated for thi
causation and
Jeffrey
28
1
PLAINTIFF S MOT10N IN LIMINE NO 17
1 purpose and to limit Nicholas Rose M D who is an orthopedist and designated to giv
2 testimony from the prospective of a chiropractic doctor
3 2 An order requiring the attorneys for all parties to instruct their witnesses of the court
4 exclusionary order on this motion and
3 An order requiring the attorney for Defendant prior to making any references comments or
5
6 assertions concerning such matters to approach the bench and make an offer of proof to the
court so that the court prior to any presentation of the above referenced evidence to the jury
7
can make a preliminary determination ofthe relevancy and admissibility thereof
9
10
DATED February 26 202Q DOLAN LAW FIRM PC
11
12 By
Christopher B Dolan Esq
13 Aimee E Kirby Esq
Cristina Garcia Esq
14 Attorneys for Plaintiff
DIEGO CONRADO
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2
PLAINTIFF S MOTION IN LIMINE NO 17
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 Aimee E Kirby SBN 216909 2 Cristina Garcia SBN 308161 DOLAN LAW FIRM PC 3 1438 Market Street v 4 San Francisco California 94102 cc tc s r Telephone 415 421 2800 5 Facsimile 415 421 2830 6 y Gerard Friend SBN 101718 3Y s 7 The Law Office of Gerard Friend 7 rr 3 r 1348 S Flower St Los Angeles CA 90015 Tel 213 689 8900 9 10 Attorneys for Plaintiff DIEGO CONRADO 11 12 SUPERIOR COURT OF THF STATE OF CALIFORNIA 13 COUNTY OF SAN BERNARDINO 14 DIEGO CONRADO an individual Case No CNDS1723453 15 Plaintiff PLAINTIFF S MOTION IN LIMINE NO 17 16 v TO EXCLUDE CUMMULATIVE EXPERT 17 TESTIMONY ON THE ISSUE OF COMPLEX CLS LANDSCAPiNG MANAGEMENT REGIONAL PAIN SYNDROME CRPS 8 1NC JOSE JUAN ESPINOZA GONZALEZ and DOES 1 to 50 Trial Date March 9 2020 9 Defendants Time 10 00 a m 20 Dept S30 I 21 22 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD HEREIN 23 PLEASE TAKE NOTICE that on March 5 2020 at 830 a m in Dept S30 of the 24 above entitled Court Plaintiff DIEGO CONRADO Plaintiff or Mr CONRADO will move this 25 Court for an issuance of the following orders in limine 26 1 An Complex Regional Pain Syndrome order limiting the hereafter CRPS diagnosis 27 damage testimony to Bounds MD who was designated for thi causation and Jeffrey 28 1 PLAINTIFF S MOT10N IN LIMINE NO 17 1 purpose and to limit Nicholas Rose M D who is an orthopedist and designated to giv 2 testimony from the prospective of a chiropractic doctor 3 2 An order requiring the attorneys for all parties to instruct their witnesses of the court 4 exclusionary order on this motion and 3 An order requiring the attorney for Defendant prior to making any references comments or 5 6 assertions concerning such matters to approach the bench and make an offer of proof to the court so that the court prior to any presentation of the above referenced evidence to the jury 7 can make a preliminary determination ofthe relevancy and admissibility thereof 9 10 DATED February 26 202Q DOLAN LAW FIRM PC 11 12 By Christopher B Dolan Esq 13 Aimee E Kirby Esq Cristina Garcia Esq 14 Attorneys for Plaintiff DIEGO CONRADO 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 PLAINTIFF S MOTION IN LIMINE NO 17