On June 22, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
Hector, Elizabeth,
and
25847 E 9Th Street, Llc,
Anza Management Company, A Corporation,
Carmona, Schochill C,
Chavez, Schochill C,
Does 2 Through 50,
J.K. Residential Services, Inc.,
Sterling Estates, A Business Entity Form Unknown,
for Personal Injury Non-Motor Vehicle Unlimited
in the District Court of San Bernardino County.
Preview
v ORIGINAL V
BINDER AND KALIOUNDJI LLP Rlofi‘gtffififim,,._,‘.TW,.,..
5%POEUNTY 5F SAN BE;:;_~-.45;'-‘pig\1so
21021 Devonshire Street, Suite 101
SAN BEWAWWO “M ‘
Chatsworth, California 91311
(818) 479-7679 ‘1“ ”I l 8 m j)
(818) 479-7690 FAX
L
r‘r
#WN : .
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-
3:,
/
DAVID S. BINDER, STATE BAR NO. 209876 BY
¢WLAURA BR‘Efi‘ZEPUTY
ZENA M. KALIOUNDJI, STATE BAR NO.: 273306
KIMBERLY JOHNSON, STATE BAR NO.: 346364
Attorneys for Defendants 25847 E. 9th STREET, LLC dba STERLING
ESTATES
APARTMENTS; SCHOCHILL CHAVEZ CARDONA (erroneously sued and served as
“Schochill C. Chavez”); and J.K. RESIDENTIAL SERVICES, INC.
\OOOQQUI
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
FOR THE COUNTY OF SAN BERNARDINO
11
12
ELIZABETH HECTOR, an individual; CASE NO.: CIVD82012799 '11
g
13 Assigned t0 Hon. Keh Winston
I"-
Plaintiff, g
Dept. S33 m
14
v '
)
)
DEFENDANTS’ MOTION IN LIMINE
U
15
16 STERLING ESTATES, a
,
busmeSS
.
entlty form
)
) N0. T0 EXCLUDE PLAINTIFF’S
2
UNAUTHENTICATED MEDICAL
w
_<
ANZA MANAGEMENT
unknown; g
RECORDS As EXHIBITS AT TRIAL;
17
COMPANY, a corporation; SCHOCHILL C.
)
MEMORANDUM OF POINTS AND —n
)
18 CHAVEZ, an individual; and DOCS 1 through ) AUTHORITIES; DECLARATION OF
50s 1n01uswe= KIMBERLY JOHNSON
19 3
Defendants. ) .
Flled: June 22, 2020
)
20
) Trial Date: July 24, 2023
21 TRC: July 20, 2023
g
22
23 TO ALL PARTIES HEREIN AND TO THEIR RESPECTIVE ATTORNEYS OF RECORD:
Defendants hereby seeks an Order requiring Plaintiff’s counsel to exclude
24
25 unauthenticated medical records as exhibits at trial. Defendants move for an order instructing
26 plaintiff and plaintiff's counsel, and requiring plaintiff‘s counsel to advise all 0f plaintiffs
27 witnesses:
28
DEFENDANT’S MOTION IN LIMINE NO. 2 T0 EXCLUDE PLAINTIFF’S UNAUTHENTICATED
MEDICAL RECORDS AS EXHIBITS AT TRIAL; MEMORANDUM OF POINTS AND
AUTHORITIES; DECLARATION OF KIMBERLY JOHNSON
Page 1 of7
1. Not to mention, refer to, or attempt to convey to the jury in any manner, either
directly or indirectly, any of the facts mentioned in this motion.
2. Not to make any reference to the fact that this motion has been filed; and;
3. To warn counsel and each and every one ofplaintiff‘s witnesses t0 strictly follow
the same instructions.
\OOOQONU‘I-D-UJN
This motion is based on this Notice, Memorandum of Points and Authorities and the
Declaration 0f Kimberly Johnson, all the pleadings, records, and files herein, and upon such
oral and documentary evidence as may be presented at the time of the hearing of this motion.
Date: July 17, 2023
10 BINDER AND KALIOUNDJI LLP
11
12 By: @5ng 9mm
KIMBERfi JéfiNSON, ESQ.
13
Attorneys for Defendants
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
DEFENDANT’S MOTION LIMINE NO. 2 TO EXCLUDE PLAINTIFF’S UNAUTHENTICATED
lN
MEDICAL RECORDS AS EXHIBITS AT TRIAL; MEMORANDUM OF POINTS AND
AUTHORITIES; DECLARATION OF KIMBERLY JOHNSON
Page 2 0f 7
Document Filed Date
July 18, 2023
Case Filing Date
June 22, 2020
Category
Personal Injury Non-Motor Vehicle Unlimited
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v ORIGINAL V BINDER AND KALIOUNDJI LLP Rlofi‘gtffififim,,._,‘.TW,.,.. 5%POEUNTY 5F SAN BE;:;_~-.45;'-‘pig\1so 21021 Devonshire Street, Suite 101 SAN BEWAWWO “M ‘ Chatsworth, California 91311 (818) 479-7679 ‘1“ ”I l 8 m j) (818) 479-7690 FAX L r‘r #WN : . ‘ - 3:, / DAVID S. BINDER, STATE BAR NO. 209876 BY ¢WLAURA BR‘Efi‘ZEPUTY ZENA M. KALIOUNDJI, STATE BAR NO.: 273306 KIMBERLY JOHNSON, STATE BAR NO.: 346364 Attorneys for Defendants 25847 E. 9th STREET, LLC dba STERLING ESTATES APARTMENTS; SCHOCHILL CHAVEZ CARDONA (erroneously sued and served as “Schochill C. Chavez”); and J.K. RESIDENTIAL SERVICES, INC. \OOOQQUI SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF SAN BERNARDINO 11 12 ELIZABETH HECTOR, an individual; CASE NO.: CIVD82012799 '11 g 13 Assigned t0 Hon. Keh Winston I"- Plaintiff, g Dept. S33 m 14 v ' ) ) DEFENDANTS’ MOTION IN LIMINE U 15 16 STERLING ESTATES, a , busmeSS . entlty form ) ) N0. T0 EXCLUDE PLAINTIFF’S 2 UNAUTHENTICATED MEDICAL w _< ANZA MANAGEMENT unknown; g RECORDS As EXHIBITS AT TRIAL; 17 COMPANY, a corporation; SCHOCHILL C. ) MEMORANDUM OF POINTS AND —n ) 18 CHAVEZ, an individual; and DOCS 1 through ) AUTHORITIES; DECLARATION OF 50s 1n01uswe= KIMBERLY JOHNSON 19 3 Defendants. ) . Flled: June 22, 2020 ) 20 ) Trial Date: July 24, 2023 21 TRC: July 20, 2023 g 22 23 TO ALL PARTIES HEREIN AND TO THEIR RESPECTIVE ATTORNEYS OF RECORD: Defendants hereby seeks an Order requiring Plaintiff’s counsel to exclude 24 25 unauthenticated medical records as exhibits at trial. Defendants move for an order instructing 26 plaintiff and plaintiff's counsel, and requiring plaintiff‘s counsel to advise all 0f plaintiffs 27 witnesses: 28 DEFENDANT’S MOTION IN LIMINE NO. 2 T0 EXCLUDE PLAINTIFF’S UNAUTHENTICATED MEDICAL RECORDS AS EXHIBITS AT TRIAL; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF KIMBERLY JOHNSON Page 1 of7 1. Not to mention, refer to, or attempt to convey to the jury in any manner, either directly or indirectly, any of the facts mentioned in this motion. 2. Not to make any reference to the fact that this motion has been filed; and; 3. To warn counsel and each and every one ofplaintiff‘s witnesses t0 strictly follow the same instructions. \OOOQONU‘I-D-UJN This motion is based on this Notice, Memorandum of Points and Authorities and the Declaration 0f Kimberly Johnson, all the pleadings, records, and files herein, and upon such oral and documentary evidence as may be presented at the time of the hearing of this motion. Date: July 17, 2023 10 BINDER AND KALIOUNDJI LLP 11 12 By: @5ng 9mm KIMBERfi JéfiNSON, ESQ. 13 Attorneys for Defendants 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DEFENDANT’S MOTION LIMINE NO. 2 TO EXCLUDE PLAINTIFF’S UNAUTHENTICATED lN MEDICAL RECORDS AS EXHIBITS AT TRIAL; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF KIMBERLY JOHNSON Page 2 0f 7