On June 22, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Hernandez Julio,
and
Bmw Of North America Llc,
Nick Alexander Imports Dba Nick Alexander Bmw,
for Contract/Warranty Breach - Seller Plaintiff (no fraud/negligence) (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
>.
© QRIGIKAL ©
BOWMAN AND BROOKE LLP
Brian Takahashi (SBN: 146505) Fi
Superior Court
Richard L. Stuhlbarg (SBN: 180631) Of Califomia
Ounty of Lo:
Theodore Dorenkamp III (SBN: 277004) 's Angeles
Jimmy Y. Park (SBN: 228290
970 lest 190th Street, Suite 700 JUL 19 2018
Torrance, California 90502 Shi
Tel No: 310/ 768-3068 By. iner/Clerk
Fax No: 310/719-1019 Deputy
1 Gomez
Attorneys for Defendants
BMW OF NORTH AMERICA, LLC and
NICK ALEXANDER IMPORTS d/b/a NICK ALEXANDER BMW
SUPERIOR COURT oF THE STATE OF CALIFORNIA
10 FOR THE COUNTY OF LOS ANGELES - STANLEY MOSK any
11
12 JULIO HERNANDEZ, CASE NO.:. BC666145
13
14 vs.,
Plaintiff, Assigned to: Hon. Michelle Williams Court
Department: 74 ‘nh
DEFENDANTS’ OPPOSITION TO oO
15 BMW OF NORTH AMERICA, LLC, a PLAINTIFF'S MOTION IN LIMINE NO. 4 TO
Delaware Limited Liability Company, EXCLUDE REFERENCE TO PLAINTIFF'S
16 NICK ALEXANDER IMPORTS, a FINANCIAL CONDITION; DECLARATION
California Corporation, d/b/a NICK OF JIMMY Y. PARK
17 ALEXANDER BMW, and DOES 1
through 10, inclusive, Action Filed: June 22, 2017
18 Trial: July 30, 2018
Defendants.
19
20
21
22 TO PLAINTIFF AND TO HIS ATTORNEYS OF RECORD:
23 Defendants BMW of North America, LLC ("BMW NA") and Nick Alexander
24 Imports dba Nick Alexander BMW submit this Opposition to Plaintiffs Motion in Limine
25 No. 4 to Exclude Reference to Plaintiff's Financial Condition.
26 I INTRODUCTION
eet Plaintiffs motion requesting the Court to exclude evidence of his financial
2
@
condition is another example of plaintiffs counsel's boilerplate motions that fails to
nD
19708949v1 1
pom DEFENDANTS’ OPPOSITION TO PLAINTIFF'S MOTION IN LIMINE NO. 4 TO EXCLUDE REFERENCE
TO PLAINTIFF'S FINANCIAL CONDITION; DECLARATION OF JIMMY Y. PARK
Document Filed Date
July 19, 2018
Case Filing Date
June 22, 2017
Category
Contract/Warranty Breach - Seller Plaintiff (no fraud/negligence) (General Jurisdiction)
Status
Jury Verdict 08/09/2019
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>. © QRIGIKAL © BOWMAN AND BROOKE LLP Brian Takahashi (SBN: 146505) Fi Superior Court Richard L. Stuhlbarg (SBN: 180631) Of Califomia Ounty of Lo: Theodore Dorenkamp III (SBN: 277004) 's Angeles Jimmy Y. Park (SBN: 228290 970 lest 190th Street, Suite 700 JUL 19 2018 Torrance, California 90502 Shi Tel No: 310/ 768-3068 By. iner/Clerk Fax No: 310/719-1019 Deputy 1 Gomez Attorneys for Defendants BMW OF NORTH AMERICA, LLC and NICK ALEXANDER IMPORTS d/b/a NICK ALEXANDER BMW SUPERIOR COURT oF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF LOS ANGELES - STANLEY MOSK any 11 12 JULIO HERNANDEZ, CASE NO.:. BC666145 13 14 vs., Plaintiff, Assigned to: Hon. Michelle Williams Court Department: 74 ‘nh DEFENDANTS’ OPPOSITION TO oO 15 BMW OF NORTH AMERICA, LLC, a PLAINTIFF'S MOTION IN LIMINE NO. 4 TO Delaware Limited Liability Company, EXCLUDE REFERENCE TO PLAINTIFF'S 16 NICK ALEXANDER IMPORTS, a FINANCIAL CONDITION; DECLARATION California Corporation, d/b/a NICK OF JIMMY Y. PARK 17 ALEXANDER BMW, and DOES 1 through 10, inclusive, Action Filed: June 22, 2017 18 Trial: July 30, 2018 Defendants. 19 20 21 22 TO PLAINTIFF AND TO HIS ATTORNEYS OF RECORD: 23 Defendants BMW of North America, LLC ("BMW NA") and Nick Alexander 24 Imports dba Nick Alexander BMW submit this Opposition to Plaintiffs Motion in Limine 25 No. 4 to Exclude Reference to Plaintiff's Financial Condition. 26 I INTRODUCTION eet Plaintiffs motion requesting the Court to exclude evidence of his financial 2 @ condition is another example of plaintiffs counsel's boilerplate motions that fails to nD 19708949v1 1 pom DEFENDANTS’ OPPOSITION TO PLAINTIFF'S MOTION IN LIMINE NO. 4 TO EXCLUDE REFERENCE TO PLAINTIFF'S FINANCIAL CONDITION; DECLARATION OF JIMMY Y. PARK