On October 26, 2016 a
Motion-Secondary
was filed
involving a dispute between
Underhill Marie,
and
Does 1 To 100,
Estate Of Testa,
for civil
in the District Court of Los Angeles County.
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OR. 3INAL
Hetal J. Kommes, State Bar No. 255838 Superior Cour! tor California
MARK R. WEINER & ASSOCIATES County of Lo: s Angeles
Employees of the Law Department
State Farm Mutual Automobile Insurance Company MAY 16 2018
655 North Central Avenue, 12" Floor Carjer, Executive UfficeriCle
rk of Court
Glendale, California 91203-1434 Sher ri
, Deputy
Telephone: (818) 543-4000
/ FAX: (855) 396-3606 Sy.
E-Mail Address: Cali.Law-Kommes@StateFarm.com
Attomeys for defendant Estate of Lynne S. Testa, Deceased,
erroneously sued and served as Estate of Testa (Deceased)
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
10
il Marie Underhill, NO. BC638507
Complaint Filed: October 26, 2016
12 Plaintiff, Judge: Hon. Dennis Landin
Department: 4
13 Vv. Trial Date: May 15, 2018
Time: 8:30 a.m.
14 Estate of Testa (Deceased) and Does | to 100, Dept: 4
15 Defendants. OPPOSITION TO PLAINTIFF’S MOTION
IN LIMINE 3 TO PRECLUDE
16 CUMULATIVE TESTIMONY;
DECLARATION OF HETAL J. KOMMES
17
18 I
19 DEFENDANT’S EXPERTS ARE NOT CUMULATIVE
20
21 Plaintiff seeks to limit defendant’s ability to call its retained experts on the grounds the
22 experts will be providing cumulative opinion testimony. Specifically, plaintiff claims that
23 defendant cannot call both a neuropsychologist and a neurologist to testify as the testimony will
24 be cumulative. That is not the case. Plaintiffs motion must be denied.
25
2
> 26 Defendant designated Charles Hinkin, Ph.D. and Jeffrey Bounds, M.D. as retained experts
27 for trial. As set out in the designation, Dr. Bound’s specialty is neurology and Dr. Hinkin is a
28 neuro-psychologist. They .will testify about plaintiff's alleged injuries and damages. However,
-1-
OPPOSITION TO PLAINTIFF’S MOTION IN LIMINE 3
Document Filed Date
May 16, 2018
Case Filing Date
October 26, 2016
Status
Jury Verdict 05/25/2018
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OR. 3INAL Hetal J. Kommes, State Bar No. 255838 Superior Cour! tor California MARK R. WEINER & ASSOCIATES County of Lo: s Angeles Employees of the Law Department State Farm Mutual Automobile Insurance Company MAY 16 2018 655 North Central Avenue, 12" Floor Carjer, Executive UfficeriCle rk of Court Glendale, California 91203-1434 Sher ri , Deputy Telephone: (818) 543-4000 / FAX: (855) 396-3606 Sy. E-Mail Address: Cali.Law-Kommes@StateFarm.com Attomeys for defendant Estate of Lynne S. Testa, Deceased, erroneously sued and served as Estate of Testa (Deceased) SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES 10 il Marie Underhill, NO. BC638507 Complaint Filed: October 26, 2016 12 Plaintiff, Judge: Hon. Dennis Landin Department: 4 13 Vv. Trial Date: May 15, 2018 Time: 8:30 a.m. 14 Estate of Testa (Deceased) and Does | to 100, Dept: 4 15 Defendants. OPPOSITION TO PLAINTIFF’S MOTION IN LIMINE 3 TO PRECLUDE 16 CUMULATIVE TESTIMONY; DECLARATION OF HETAL J. KOMMES 17 18 I 19 DEFENDANT’S EXPERTS ARE NOT CUMULATIVE 20 21 Plaintiff seeks to limit defendant’s ability to call its retained experts on the grounds the 22 experts will be providing cumulative opinion testimony. Specifically, plaintiff claims that 23 defendant cannot call both a neuropsychologist and a neurologist to testify as the testimony will 24 be cumulative. That is not the case. Plaintiffs motion must be denied. 25 2 > 26 Defendant designated Charles Hinkin, Ph.D. and Jeffrey Bounds, M.D. as retained experts 27 for trial. As set out in the designation, Dr. Bound’s specialty is neurology and Dr. Hinkin is a 28 neuro-psychologist. They .will testify about plaintiff's alleged injuries and damages. However, -1- OPPOSITION TO PLAINTIFF’S MOTION IN LIMINE 3