On May 13, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Kosai Samantha,
and
Staff Pro Inc.,
University Of Southern California,
for Personal Injury/Property Damage/Wrongful Death - Uninsured Motorist (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 03/22/2022 06:54 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,Deputy Clerk
1 Kathy A. Hunt (State Bar No. 146454)
kak@manningllp.com
2 MANNING & KASS
ELLROD, RAMIREZ, TRESTER LLP
3 801 S. Figueroa St, 15th Floor
Los Angeles, California 90017-3012
4 Telephone: (213) 624-6900
Facsimile: (213) 624-6999
5 Attorneys for Defendants University of Southern
California; Staff Pro, Inc.
6
7
SUPERIOR COURT OF THE STATE OF CALIFORNIA
8
COUNTY OF LOS ANGELES, CENTRAL DISTRICT
9
10
SAMANTHA KOSAI, Case No. 19STCV16679
11 [ASSIGNED FOR ALL PURPOSES TO
Plaintiff, DEPT. 32, Hon. Whitaker, Michael E.]
12
v. DEFENDANTS’ MOTION IN LIMINE
13 NO. 5 TO EXCLUDE UNQUALIFIED
UNIVERSITY OF SOUTHERN LAY WITNESS OPINIONS
14 CAILFORNIA; STAFF PRO, INC.; AND
DOES 1 TO 50, INCLUSIVE, Filed Concurrently with Declaration of
15 Kathleen Hunt; [Proposed] Order
Defendants.
16 Date: April 14, 2022
Time: 10:00 a.m.
17
Action Filed: 5/13/19
18 Trial Date: 04/28/2022
19 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
20 Defendants University of Southern California and Staff Pro, Inc. (“Defendants”), before
21 trial and the selection of the jury in this action, move this Court in limine for the following orders:
22 1. To preclude Plaintiff Samantha Kosai (“Plaintiff”) and her counsel from referring
23 to, interrogate concerning, commenting on, attempting to elicit or suggest to the jury, attempt to
24 introduce in any way as evidence, or argue to the jury, any expert opinions or conclusions elicited
25 from lay witnesses, including Plaintiff, who were not designated or are not qualified to offer
26 expert opinions or conclusions on the topic; and
27 2. That Plaintiff and her counsel direct persons under their control, including, any
28 associates and witnesses, and persons associated with Plaintiffs, to comply with the above
4865-2148-9687.1
MOTION IN LIMINE NO. 5
Document Filed Date
March 22, 2022
Case Filing Date
May 13, 2019
Category
Personal Injury/Property Damage/Wrongful Death - Uninsured Motorist (General Jurisdiction)
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Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 03/22/2022 06:54 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,Deputy Clerk 1 Kathy A. Hunt (State Bar No. 146454) kak@manningllp.com 2 MANNING & KASS ELLROD, RAMIREZ, TRESTER LLP 3 801 S. Figueroa St, 15th Floor Los Angeles, California 90017-3012 4 Telephone: (213) 624-6900 Facsimile: (213) 624-6999 5 Attorneys for Defendants University of Southern California; Staff Pro, Inc. 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 COUNTY OF LOS ANGELES, CENTRAL DISTRICT 9 10 SAMANTHA KOSAI, Case No. 19STCV16679 11 [ASSIGNED FOR ALL PURPOSES TO Plaintiff, DEPT. 32, Hon. Whitaker, Michael E.] 12 v. DEFENDANTS’ MOTION IN LIMINE 13 NO. 5 TO EXCLUDE UNQUALIFIED UNIVERSITY OF SOUTHERN LAY WITNESS OPINIONS 14 CAILFORNIA; STAFF PRO, INC.; AND DOES 1 TO 50, INCLUSIVE, Filed Concurrently with Declaration of 15 Kathleen Hunt; [Proposed] Order Defendants. 16 Date: April 14, 2022 Time: 10:00 a.m. 17 Action Filed: 5/13/19 18 Trial Date: 04/28/2022 19 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 20 Defendants University of Southern California and Staff Pro, Inc. (“Defendants”), before 21 trial and the selection of the jury in this action, move this Court in limine for the following orders: 22 1. To preclude Plaintiff Samantha Kosai (“Plaintiff”) and her counsel from referring 23 to, interrogate concerning, commenting on, attempting to elicit or suggest to the jury, attempt to 24 introduce in any way as evidence, or argue to the jury, any expert opinions or conclusions elicited 25 from lay witnesses, including Plaintiff, who were not designated or are not qualified to offer 26 expert opinions or conclusions on the topic; and 27 2. That Plaintiff and her counsel direct persons under their control, including, any 28 associates and witnesses, and persons associated with Plaintiffs, to comply with the above 4865-2148-9687.1 MOTION IN LIMINE NO. 5