On June 20, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Thomas Carolyn,
and
Contreras Grecia,
Does 1 To 100,
The Adult Skills Center,
for Elder/Dependent Adult Abuse Case (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
e @
Louis W. Pappas (State Bar No. 118140)
Michael H. Cooper (State Bar No. 272124) LED
Superior Court of California
MANNING & KASS
ELLROD, RAMIREZ, TRESTER LLP County of Los Angeles
801 S. Figueroa St, 15" Floor
Los Angeles, California 90017-3012 JUN 07 2018
Telephone: (213) 624-6900 Sherri R, Carter, Executive Ulficer/
Facsimile: (213) 624-6999 Clerk
By. Fhorte | Deputy
Attorneys for THE ADULT SKILLS CENTER, Heather Flores
A California Non-Profit Corporation
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES, CENTRAL DISTRICT
10
11
CAROLYN THOMAS, an Individual, Case No. BC665771
12 [Unlimited Civil Action]
B38 Plaintiff, [Assigned to the Honorable Richard L Fruin,
13 Dept. 15]
wi33
Qe Vv.
Se 14 DEFENDANT THE ADULT SKILLS
THE ADULT SKILLS CENTER, A California CENTER'S MOTION IN LIMINE NO. 15
as 15 Non-Profit Corporation, GRECIA
CONTRERAS, an Individual, and DOES 1 to
TO EXCLUDE THE TESTIMONY OF
PLAINTIFF'S EXPERT STACEY WOOD,
16 100, Inclusive, Ph.D.; MEMORANDUM OF POINTS AND
AUTHORITIES; DECLARATION OF
17 Defendants. MICHAEL H. COOPER
18 Action Filed: June 20, 2017
Trial Date: June 25, 2018
19
20 TO THE COURT, ALL PARTIES AND THEIR COUNSEL OF RECORD:
21 PLEASE TAKE NOTICE that Defendant THE ADULT SKILLS CENTER moves the
22 court in limine for an order to exclude the testimony of plaintiff's retained expert Stacey Wood,
23 Ph.D. on the grounds that Dr. Wood's testimony is improper expert opinion testimony, irrelevant,
24 unduly prejudicial, would necessitate an undue consumption of time, cause confusion and mislead
25 the jurors.
a
gt
26 Defendant further moves the court to instruct plaintiff and plaintiff's counsel and to require
a
mat
27 counsel to advise all of plaintiff's witnesses:
me
et
o 28 1 Not to attempt to convey to the jury, directly or indirectly, any of the facts
or
DEFENDANT THE ADULT SKILLS CENTER'S MOTION IN LIMINE NO. 15
Document Filed Date
June 07, 2018
Case Filing Date
June 20, 2017
Category
Elder/Dependent Adult Abuse Case (General Jurisdiction)
Status
Jury Verdict 11/26/2018
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