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 10/18/2022 11:18 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk
1 ROB HENNIG (STATE BAR NO. 174646)
SAM BROWN (STATE BAR NO. 308558)
2 HENNIG KRAMER RUIZ & SINGH, LLP
3 3600 WILSHIRE BLVD., SUITE 1908
LOS ANGELES, CA 90010
4 PHONE: (213) 310-8301
FAX: (213) 310-8302
5
Attorneys for Plaintiff Annette Sierra
6
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF LOS ANGELES, UNLIMITED JURISDICTION
10
11 ANNETTE SIERRA, an individual, CASE NO. BC 688510
12 Plaintiff, [Assigned to Hon. Robert B. Broadbelt]
Dept. 53]
13 vs.
PLAINTIFF’S MOTION IN LIMINE NO.1:
14 THE CITY OF LOS ANGELES, a public TO EXCLUDE ALL TESTIMONY AND
entity; and DOES 1 through 40, inclusive, EVIDENCE REGARDING ANY ALLEGED
15 NEGATIVE, DEFICIENT, OR
Defendants. UNSATISFACTORY JOB PERFORMANCE
16 OF PLAINTIFF; DECLARATION OF SAM
BROWN
17
18 Action Filed: December 27, 2017
FSC Date: October 28, 2022
19 Trial Date: November 16, 2022
20
21
22 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD IN THIS ACTION:
23 PLEASE TAKE NOTICE THAT on October 28, 2022 at 11:00 a.m., or as soon thereafter
24 as counsel can be heard, Plaintiff ANNETTE SIERRA (“Plaintiff” or “Sierra”) will make a
25 Motion in limine (Number 1) for an order excluding evidence or testimony regarding any alleged,
26 negative, deficient and/or or unsatisfactory job performance by Plaintiff, including but not limited
27 to her time in the Truancy Prevention Program (“TPP”) while she worked for Defendant THE
28 CITY OF LOS ANGELES (“Defendant” or “COLA”). Plaintiff’s job performance—particularly
1
PLAINTIFF’S MOTION IN LIMINE NO. 1
Document Filed Date
October 18, 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 10/18/2022 11:18 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk 1 ROB HENNIG (STATE BAR NO. 174646) SAM BROWN (STATE BAR NO. 308558) 2 HENNIG KRAMER RUIZ & SINGH, LLP 3 3600 WILSHIRE BLVD., SUITE 1908 LOS ANGELES, CA 90010 4 PHONE: (213) 310-8301 FAX: (213) 310-8302 5 Attorneys for Plaintiff Annette Sierra 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES, UNLIMITED JURISDICTION 10 11 ANNETTE SIERRA, an individual, CASE NO. BC 688510 12 Plaintiff, [Assigned to Hon. Robert B. Broadbelt] Dept. 53] 13 vs. PLAINTIFF’S MOTION IN LIMINE NO.1: 14 THE CITY OF LOS ANGELES, a public TO EXCLUDE ALL TESTIMONY AND entity; and DOES 1 through 40, inclusive, EVIDENCE REGARDING ANY ALLEGED 15 NEGATIVE, DEFICIENT, OR Defendants. UNSATISFACTORY JOB PERFORMANCE 16 OF PLAINTIFF; DECLARATION OF SAM BROWN 17 18 Action Filed: December 27, 2017 FSC Date: October 28, 2022 19 Trial Date: November 16, 2022 20 21 22 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD IN THIS ACTION: 23 PLEASE TAKE NOTICE THAT on October 28, 2022 at 11:00 a.m., or as soon thereafter 24 as counsel can be heard, Plaintiff ANNETTE SIERRA (“Plaintiff” or “Sierra”) will make a 25 Motion in limine (Number 1) for an order excluding evidence or testimony regarding any alleged, 26 negative, deficient and/or or unsatisfactory job performance by Plaintiff, including but not limited 27 to her time in the Truancy Prevention Program (“TPP”) while she worked for Defendant THE 28 CITY OF LOS ANGELES (“Defendant” or “COLA”). Plaintiff’s job performance—particularly 1 PLAINTIFF’S MOTION IN LIMINE NO. 1