On June 22, 2017 a
Exhibit,Appendix
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
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QRIGINAL
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BOWMAN AND BROOKE LLP
Brian Takahashi (SBN: 146505
Richard L. Stuhlbarg (SBN: 180631
Theodore Dorenkamp III (SBN: 277004) FI
Superior Court
Jimmy Y. Park (SBN: 228290) Of California
970 est 190th Street, Suite 700 ‘Ounty of Lo: s Angeles
Torrance, California 90502
Tel No: 310/ 768-3068 Ju 15319
Fax No: 310/719-1019 Shi
By. icer/Clerk
Deputy
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
1
ui
12 JULIO HERNANDEZ, CASE NO.: BC666145 yoy
13 Plaintiff, Assigned to: Hon. Michelle Williams Court
Department:
14 vs.
15 BMW OF NORTH AMERICA, LLC, a
DEFENDANTS’ OPPOSITION TO
PLAINTIFF'S MOTION IN LIMINE NO. 2 TO al
16
Delaware Limited Liability Company,
NICK ALEXANDER IMPORTS, a
EXCLUDE REFERENCE TO ATTORNEY'S
FEES; DECLARATION OF JIMMY Y. D®
California Corporation, d/b/a NICK PARK; EXHIBITS "A" ~"B"
17 ALEXANDER BMW, and DOES 1
through 10, inclusive, Action Filed: June 22, 2017
18 Trial: July 30,2018
Defendants.
19
20
21
TO PLAINTIFF AND TO HIS ATTORNEYS OF RECORD:
22
Defendants BMW of North America, LLC and Nick Alexander Imports dba Nick
23
Alexander BMW submit this opposition to plaintiffs Motion in Limine No. 2 to Exclude
24
Reference to Attorney's Fees.
25
I INTRODUCTION
26
Based upon past experience, there is a risk that plaintiff counsel may attempt to
2%
“dl mislead the jury in opening, closing argument and throughout the trial by falsely
28:Pa
3
hed 19705846v1
4
pee DEFENDANTS' OPPOSITION TO PLAINTIFF'S MOTION IN LIMINE NO. 2 TO EXCLUDE REFERENCE
TO ATTORNEY'S FEES; DECLARATION JIMMY Y. PARK; EXHIBITS "A" -"B"
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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Preview
e QRIGINAL tf BOWMAN AND BROOKE LLP Brian Takahashi (SBN: 146505 Richard L. Stuhlbarg (SBN: 180631 Theodore Dorenkamp III (SBN: 277004) FI Superior Court Jimmy Y. Park (SBN: 228290) Of California 970 est 190th Street, Suite 700 ‘Ounty of Lo: s Angeles Torrance, California 90502 Tel No: 310/ 768-3068 Ju 15319 Fax No: 310/719-1019 Shi By. icer/Clerk Deputy 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 1 ui 12 JULIO HERNANDEZ, CASE NO.: BC666145 yoy 13 Plaintiff, Assigned to: Hon. Michelle Williams Court Department: 14 vs. 15 BMW OF NORTH AMERICA, LLC, a DEFENDANTS’ OPPOSITION TO PLAINTIFF'S MOTION IN LIMINE NO. 2 TO al 16 Delaware Limited Liability Company, NICK ALEXANDER IMPORTS, a EXCLUDE REFERENCE TO ATTORNEY'S FEES; DECLARATION OF JIMMY Y. D® California Corporation, d/b/a NICK PARK; EXHIBITS "A" ~"B" 17 ALEXANDER BMW, and DOES 1 through 10, inclusive, Action Filed: June 22, 2017 18 Trial: July 30,2018 Defendants. 19 20 21 TO PLAINTIFF AND TO HIS ATTORNEYS OF RECORD: 22 Defendants BMW of North America, LLC and Nick Alexander Imports dba Nick 23 Alexander BMW submit this opposition to plaintiffs Motion in Limine No. 2 to Exclude 24 Reference to Attorney's Fees. 25 I INTRODUCTION 26 Based upon past experience, there is a risk that plaintiff counsel may attempt to 2% “dl mislead the jury in opening, closing argument and throughout the trial by falsely 28:Pa 3 hed 19705846v1 4 pee DEFENDANTS' OPPOSITION TO PLAINTIFF'S MOTION IN LIMINE NO. 2 TO EXCLUDE REFERENCE TO ATTORNEY'S FEES; DECLARATION JIMMY Y. PARK; EXHIBITS "A" -"B"