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 luperior Court of California, County of Los Angeles on 11/08/2022 03:24 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk
LINDA MILLER SAVITT, SBN 94164
lsavitt@brgslaw.com
PHILIP L. REZNIK, SBN 204590
preznik@brgslaw.com
BALLARD ROSENBERG GOLPER & SAVITT, LLP
15760 Ventura Boulevard, 18"" Floor
Encino, CA 91436
Telephone: (818) 508-3700
Facsimile: (818) 506-4827
Attorneys for Defendant
CITY OF LOS ANGELES
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES
10 ANNETTE SIERRA, an individual, CASE NO. BC 688510
mex 11 Plaintiff, [Assigned to Hon. Robert B. Broadbelt]
28
aa Dept. 53]
Ge 12 vs.
Be DEFENDANT CITY OF LOS ANGELES'
eS 13 THE CITY OF LOS ANGELES, a public MOTION IN LIMINE NO 1 TO
entity; and DOES 1| through 40, inclusive, EXCLUDE EVIDENCE OF PLAINTIFF'S
2
2S 14
Se
ad
PERFORMANCE OF ESSENTIAL
mee Defendants. DUTIES OF DISSIMILAR, OFFICE-
B85
as 15
meag BASED ASSIGNMENT PRIOR TO HER
meaBg TRANSFER TO TRUANCY
Be 16 PROTECTION PROGRAM ("TPP") IN
NOVEMBER 2014; DECLARATION OF
17 PHILIP L. REZNIK
18 Date; October 14, 2021
Time: 8:30 a.m.
19 Dept.: 53
20 Action Filed: December 27, 2017
TRIAL: November 16, 2022
21 FSC: October 28, 2022
22
23 Defendant CITY OF LOS ANGELES ("City") hereby moves in limine to preclude the
24 introduction of any evidence or argument in in the presence of the jury at trial regarding Plaintiff's
25 performance of the essential functions of a Deputy City Attorney ("DCA") in the office-based
26 assignments she held prior to her reassignment to a fieldwork-based assignment in the Truancy
27 Protection Program ("TPP") in November 2014, on grounds that:
28 1 Any claims of failure to accommodate or to engage in the interactive process prior to
1936968.1 1
City's MIL No. 1 RE: PLAINTIFF'S ASSIGNMENTS PRIOR TO TRUANCY PREVENTION PROGRAM
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 luperior Court of California, County of Los Angeles on 11/08/2022 03:24 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk LINDA MILLER SAVITT, SBN 94164 lsavitt@brgslaw.com PHILIP L. REZNIK, SBN 204590 preznik@brgslaw.com BALLARD ROSENBERG GOLPER & SAVITT, LLP 15760 Ventura Boulevard, 18"" Floor Encino, CA 91436 Telephone: (818) 508-3700 Facsimile: (818) 506-4827 Attorneys for Defendant CITY OF LOS ANGELES SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES 10 ANNETTE SIERRA, an individual, CASE NO. BC 688510 mex 11 Plaintiff, [Assigned to Hon. Robert B. Broadbelt] 28 aa Dept. 53] Ge 12 vs. Be DEFENDANT CITY OF LOS ANGELES' eS 13 THE CITY OF LOS ANGELES, a public MOTION IN LIMINE NO 1 TO entity; and DOES 1| through 40, inclusive, EXCLUDE EVIDENCE OF PLAINTIFF'S 2 2S 14 Se ad PERFORMANCE OF ESSENTIAL mee Defendants. DUTIES OF DISSIMILAR, OFFICE- B85 as 15 meag BASED ASSIGNMENT PRIOR TO HER meaBg TRANSFER TO TRUANCY Be 16 PROTECTION PROGRAM ("TPP") IN NOVEMBER 2014; DECLARATION OF 17 PHILIP L. REZNIK 18 Date; October 14, 2021 Time: 8:30 a.m. 19 Dept.: 53 20 Action Filed: December 27, 2017 TRIAL: November 16, 2022 21 FSC: October 28, 2022 22 23 Defendant CITY OF LOS ANGELES ("City") hereby moves in limine to preclude the 24 introduction of any evidence or argument in in the presence of the jury at trial regarding Plaintiff's 25 performance of the essential functions of a Deputy City Attorney ("DCA") in the office-based 26 assignments she held prior to her reassignment to a fieldwork-based assignment in the Truancy 27 Protection Program ("TPP") in November 2014, on grounds that: 28 1 Any claims of failure to accommodate or to engage in the interactive process prior to 1936968.1 1 City's MIL No. 1 RE: PLAINTIFF'S ASSIGNMENTS PRIOR TO TRUANCY PREVENTION PROGRAM