On June 22, 2017 a
Party Discovery
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.
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@ e ORIGINAL
BOWMAN AND BROOKE LLP
Brian Takahashi (SBN: 146505
Richard L. Stuhlbarg (SBN: 180631)
Theodore Dorenkamp Ill (SBN: 277004) FILED
Superior Court of California
Jimmy Y. Park (SBN: 228290) County af tne Anoeles
970 fest 190th Street, Suite 700
Torrance, California 90502
Tel No: 310/ 768-3068 JUL 13 2018
Fax No: 310/719-1019 Sherri. Ca fC Utnicer/Clerk of Court
By. = Dent
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
11
12 JULIO HERNANDEZ, CASE NO.: BC666145
13 Plaintiff, ) Assigned to: Hon. Michelle Williams Court
Department: 74
14 vs. )
DEFENDANTS' MOTION IN _LIMINE NO. 8
15 BMW OF NORTH AMERICA, LLC, a ) FOR_AN ORDER TO LIMIT PLAINTIFF'S
Delaware Limited Liabili Company, ) EXPERT TO HIS DEPOSITION OPINIONS;
16 NICK ALEXANDER | PORTS, a MEMORANDUM __ OF POINTS AND
California Corporation, d/b/a NICK ) AUTHORITIES; DECLARATION OF JIMMY
17 ALEXANDER BMW, and DOES 1 ) Y. PARK; [PROPOSED] ORDER
through 10, inclusive,
18 Motion in Limine No. 8
Defendants. ) Action Filed: June 22, 2017
19
) tial: July 30, 2018
20
21 TO PLAINTIFF AND TO HIS ATTORNEYS OF RECORD:
22 Defendants BMW OF NORTH AMERICA, LLC and NICK ALEXANDER
23 IMPORTS dba NICK ALEXANDER BMW move this Court in limine for an order to limit
24 plaintiffs expert to his deposition opinions. (Kennemur v. State of California (1982) 133
25 Cal.App.3d 907.) More specifically, BMW NA seeks an order in limine that: (1)
26 plaintiffs expert only be permitted to testify as to those opinions and conclusions
A
27.ee testified to in his deposition; (2) excludes testimony based upon materials not reviewed
28 or provided at the deposition of that expert; and (3) prohibits plaintiff from mentioning,
©
—
19685001v2 1
DEFENDANTS' MOTION IN LIMINE NO. 8 FOR AN ORDER TO LIMIT PLAINTIFF'S EXPERT TO HIS
DEPOSITION OPINIONS; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF
JIMMY Y. PARK; [PROPOSED] ORDER
Document Filed Date
July 13, 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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@ e ORIGINAL BOWMAN AND BROOKE LLP Brian Takahashi (SBN: 146505 Richard L. Stuhlbarg (SBN: 180631) Theodore Dorenkamp Ill (SBN: 277004) FILED Superior Court of California Jimmy Y. Park (SBN: 228290) County af tne Anoeles 970 fest 190th Street, Suite 700 Torrance, California 90502 Tel No: 310/ 768-3068 JUL 13 2018 Fax No: 310/719-1019 Sherri. Ca fC Utnicer/Clerk of Court By. = Dent 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 11 12 JULIO HERNANDEZ, CASE NO.: BC666145 13 Plaintiff, ) Assigned to: Hon. Michelle Williams Court Department: 74 14 vs. ) DEFENDANTS' MOTION IN _LIMINE NO. 8 15 BMW OF NORTH AMERICA, LLC, a ) FOR_AN ORDER TO LIMIT PLAINTIFF'S Delaware Limited Liabili Company, ) EXPERT TO HIS DEPOSITION OPINIONS; 16 NICK ALEXANDER | PORTS, a MEMORANDUM __ OF POINTS AND California Corporation, d/b/a NICK ) AUTHORITIES; DECLARATION OF JIMMY 17 ALEXANDER BMW, and DOES 1 ) Y. PARK; [PROPOSED] ORDER through 10, inclusive, 18 Motion in Limine No. 8 Defendants. ) Action Filed: June 22, 2017 19 ) tial: July 30, 2018 20 21 TO PLAINTIFF AND TO HIS ATTORNEYS OF RECORD: 22 Defendants BMW OF NORTH AMERICA, LLC and NICK ALEXANDER 23 IMPORTS dba NICK ALEXANDER BMW move this Court in limine for an order to limit 24 plaintiffs expert to his deposition opinions. (Kennemur v. State of California (1982) 133 25 Cal.App.3d 907.) More specifically, BMW NA seeks an order in limine that: (1) 26 plaintiffs expert only be permitted to testify as to those opinions and conclusions A 27.ee testified to in his deposition; (2) excludes testimony based upon materials not reviewed 28 or provided at the deposition of that expert; and (3) prohibits plaintiff from mentioning, © — 19685001v2 1 DEFENDANTS' MOTION IN LIMINE NO. 8 FOR AN ORDER TO LIMIT PLAINTIFF'S EXPERT TO HIS DEPOSITION OPINIONS; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF JIMMY Y. PARK; [PROPOSED] ORDER