Motion,Ex Parte: SCOT R MENDELSON VS JOHNNY REYES ET AL

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                                FREEMAN MATHIS & GARY, LLP
                                                        ORIGINAL
                           RONALD MA WHINNEY / Bar No. 181982                                                 Fits
                           550 South Hope Street, 22nd Floor
                           Los Angeles, California 90071-2627                                            Ounty of los,
                                                                                                                   rt of   Clifomig
                           (213) 615-7000; FAX (213) 615-7100

                           Attorneys for Defendants                                                      JAN 19 2079
                              HHNNY REYES, MARIA REYES
                       5                                                                                                   Micer/cy
                       6                                                                                                      Deputy


                                               SUPERIOR COURT OF THE STATE OF CALIFORNIA
                                                         FOR THE COUNTY OF LOS ANGELES


                           SCOT R. MENDELSON, an individual,                     ) Case No. BC632977
                                                                                 ) Dept.: 92
                                           Plaintiff,
                                   V.                                            ) DEFENDANTS' MOTION IN LIMINE
                                                                                 ) NO.      4TO EXCLUDE ANY EXPERT
                           JOHNNY REYES, an individual; MARIA                    )   AND/OR EXPERT OPINION NOT
                      14   REYES, an individual and DOES 1-25, inclusive,        )   PREVIOUSLY DISCLOSED;
                                                                                 )   MEMORANDUM OF POINT AND
                      15                   Defendants.                           )   AUTHORTIES; DECLARATION OF
                                                                                 )   RONALD MAWHINNEY
                      16
                                                                                     Complaint Filed:   September 6, 2016
                      17                                                             Trial Date:        March 6, 2018
                      18   TO: ALL PARTIES HEREIN AND TO THEIR RESPECTIVE COUNSEL OF RECORD:

                      19           Defendants JOHNNY REYES and MARIA REYES (“Defendants”) hereby move the court
                      20   for a pre-trial order precluding plaintiff SCOT R. MENDELSON (“Plaintiff”) and Plaintiff's
                      21   counsel not to refer to, interrogate any witness concerning, comment on, attempt to suggest to the
                      22   jury, in any way, (including, but not limited to voir dire of the jury) any and all expert testimony

                      23   and/or expert reports, measurements or documentation not produced or properly submitted to

                      24   defendant prior to trial pursuant to California Code of Civil Procedure § 2034.210 et seq.
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be                    25           This Motion is also made pursuant to California Code of Civil Procedure §2034.300, on the
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bad                   26   grounds that such testimony would violate California law and would be highly prejudicial in that it
ba?
oe                    27   would frustrate the entire purpose of pre-trial expert witness discovery.
per   Freeman Matis
ae      Gan.>
      ‘nomeye at aw   28           This Motion is based upon the attached memorandum of points and authorities in support of

                             DEFENDANTS' MOTION IN LIMINE NO. 4 TO EXCLUDE ANY EXPERT AND/OR EXPERT OPINION NOT
                                                            PREVIOUSLY DISCLOSED
                           4615857. 11139-68946 RLM