On December 27, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Sierra Annette,
and
The City Of Los Angeles,
for Other Employment Complaint Case (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 11/08/2022 03:28 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk
[Exempt From Filing Fees – Govt. Code § 6103]
1 LINDA MILLER SAVITT, SBN 94164
lsavitt@brgslaw.com
2 PHILIP L. REZNIK, SBN 204590
preznik@brgslaw.com
3 BALLARD ROSENBERG GOLPER & SAVITT, LLP
15760 Ventura Boulevard, 18th Floor
4 Encino, CA 91436
Telephone: (818) 508-3700
5 Facsimile: (818) 506-4827
6 Attorneys for Defendant
CITY OF LOS ANGELES
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF LOS ANGELES
10 ANNETTE SIERRA, an individual, CASE NO. BC 688510
BALLARD ROSENBERG GOLPER & SAVITT, LLP
11 Plaintiff, [Assigned to Hon. Robert B. Broadbelt]
Dept. 53]
15760 VENTURA BOULEVARD, EIGHTEENTH FLOOR
12 vs.
DEFENDANT CITY OF LOS ANGELES'
ENCINO, CALIFORNIA 91436
13 THE CITY OF LOS ANGELES, a public MOTION IN LIMINE NO 3 TO
entity; and DOES 1 through 40, inclusive, EXCLUDE EVIDENCE OR ARGUMENT
14 REGARDING ACCOMMODATION OF
Defendants. OTHER DISABLED EMPLOYEES IN
15 DIFFERENT JOBS WITH DIFFERENT
DISABILITIES; DECLARATION OF
16 PHILIP L. REZNIK
17 Date; October 14, 2021
Time: 8:30 a.m.
18 Dept.: 53
19 Action Filed: December 27, 2017
TRIAL: August 17, 2022
20 FSC: August 4, 2022
21
22 Defendant CITY OF LOS ANGELES ("City") hereby moves in limine to preclude the
23 introduction of any evidence or argument in in the presence of the jury at trial regarding the
24 accommodation of disabled employees in different jobs with different disabilities, including former
25 Senior Management Analyst Betty Wilson and former Legal Clerk William Dykens.
26 The City moves to exclude such evidence on grounds that allowing such evidence would
27 require "mini-trials" to establish the job duties, work restrictions and accommodations provided to
28 such employees and the extent to which they are or are not comparable to Plaintiff's job duties,
1939866.1 1
CITY'S MIL NO. 3 RE: DISABLED EMPLOYEES IN DIFFERENT JOBS WITH DIFFERENT DISABILITIES
Document Filed Date
November 08, 2022
Case Filing Date
December 27, 2017
Category
Other Employment Complaint Case (General Jurisdiction)
Status
Request for Dismissal - Before Trial not following ADR or more than 60 days since ADR 11/13/2023
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Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 11/08/2022 03:28 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk [Exempt From Filing Fees – Govt. Code § 6103] 1 LINDA MILLER SAVITT, SBN 94164 lsavitt@brgslaw.com 2 PHILIP L. REZNIK, SBN 204590 preznik@brgslaw.com 3 BALLARD ROSENBERG GOLPER & SAVITT, LLP 15760 Ventura Boulevard, 18th Floor 4 Encino, CA 91436 Telephone: (818) 508-3700 5 Facsimile: (818) 506-4827 6 Attorneys for Defendant CITY OF LOS ANGELES 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF LOS ANGELES 10 ANNETTE SIERRA, an individual, CASE NO. BC 688510 BALLARD ROSENBERG GOLPER & SAVITT, LLP 11 Plaintiff, [Assigned to Hon. Robert B. Broadbelt] Dept. 53] 15760 VENTURA BOULEVARD, EIGHTEENTH FLOOR 12 vs. DEFENDANT CITY OF LOS ANGELES' ENCINO, CALIFORNIA 91436 13 THE CITY OF LOS ANGELES, a public MOTION IN LIMINE NO 3 TO entity; and DOES 1 through 40, inclusive, EXCLUDE EVIDENCE OR ARGUMENT 14 REGARDING ACCOMMODATION OF Defendants. OTHER DISABLED EMPLOYEES IN 15 DIFFERENT JOBS WITH DIFFERENT DISABILITIES; DECLARATION OF 16 PHILIP L. REZNIK 17 Date; October 14, 2021 Time: 8:30 a.m. 18 Dept.: 53 19 Action Filed: December 27, 2017 TRIAL: August 17, 2022 20 FSC: August 4, 2022 21 22 Defendant CITY OF LOS ANGELES ("City") hereby moves in limine to preclude the 23 introduction of any evidence or argument in in the presence of the jury at trial regarding the 24 accommodation of disabled employees in different jobs with different disabilities, including former 25 Senior Management Analyst Betty Wilson and former Legal Clerk William Dykens. 26 The City moves to exclude such evidence on grounds that allowing such evidence would 27 require "mini-trials" to establish the job duties, work restrictions and accommodations provided to 28 such employees and the extent to which they are or are not comparable to Plaintiff's job duties, 1939866.1 1 CITY'S MIL NO. 3 RE: DISABLED EMPLOYEES IN DIFFERENT JOBS WITH DIFFERENT DISABILITIES