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  • ARMAN TASCI VS B&V ENTERPRISES INC Premises Liability (e.g.slip & fall) (General Jurisdiction) document preview
  • ARMAN TASCI VS B&V ENTERPRISES INC Premises Liability (e.g.slip & fall) (General Jurisdiction) document preview
						
                                

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Electronically FILED by Superior Court of California, County of Los Angeles on 09/12/2019 07:11 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,Deputy Clerk 1 Jeffrey M. Lenkov, Esq. (State Bar No. 156478) jml@manningllp.com 2 David Breitburg, Esq. (State Bar No. 105511) dxb@manningllp.com 3 Brandon Dawoodtabar, Esq. (State Bar No. 318786) bxd@manningllp.com 4 MANNING & KASS ELLROD, RAMIREZ, TRESTER LLP 5 801 S. Figueroa St, 15th Floor Los Angeles, California 90017-3012 6 Telephone: (213) 624-6900 Facsimile: (213) 624-6999 7 Attorneys for Defendant, B&V Enterprises, Inc. 8 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF LOS ANGELES, CENTRAL DISTRICT 11 12 ARMAN TASCI, Case No. BC667483 13 Plaintiff, DEFENDANT’S MOTION IN LIMINE NO. 1 TO LIMIT RECOVERY FOR 14 v. MEDICAL SPECIAL DAMAGES AND FUTURE MEDICAL SPECIAL 15 B&V ENTERPRISES, INC., DAMAGES TO AMOUNT PAID, NOT THE AMOUNT BILLED; 16 Defendant. MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF 17 BRANDON DAWOODTABAR 18 Dept.: 4B 19 Complaint Filed: July 7, 2017 Trial Date: October 18, 2019 20 21 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 22 Defendant B&V Enterprises, Inc., (“Defendant”), before trial and the selection of the jury 23 in this action, moves this Court in limine for the following orders: 24 1. The amount of medical specials presented to the jury shall be limited to amounts 25 either actually paid to Plaintiff ARMAN TASCI’S (“Plaintiff”) health care providers, or the 26 reasonable value of the services, and shall not include the full amount originally billed; 27 2. That Plaintiff direct persons under his control, including, any associates and 28 witnesses, and persons associated with Plaintiffs, to comply with the above referenced order, in all 1 DEFENDANT’S MOTION IN LIMINE NO. 1 TO LIMIT RECOVERY FOR MEDICAL SPECIAL DAMAGES AND FUTURE DAMAGES TO AMOUNTS PAID, NOT AMOUNTS BILLED