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  • MARIE UNDERHILL VS ESTATE OF TESTA Premises Liablty (e.g. slip & fall (General Jurisdiction) document preview
  • MARIE UNDERHILL VS ESTATE OF TESTA Premises Liablty (e.g. slip & fall (General Jurisdiction) document preview
						
                                

Preview

Hetal J. Kommes, State Bar No. 255838 MARK R. WEINER & ASSOCIATES FILED Superior Court of California Employees of the Law Department County of fas Anoeles State Farm Mutual Automobile Insurance Company 655 North Central Avenue, 12" Floor MAY 14 2018 Glendale, California 91203-1434 < Telephone: (818) 543-4000/ FAX: (855) 396-3606 Sherri R. Ca er, Executive Officer/Clerk of Court E-Mail Address: Cali.Law-Kommes@StateFarm.com By. +Deputy Raul Sanchez Attorneys 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 : S5e. 4 13 Vv. Trial Date: May 15, 2018 Time 8:30 a.m. 14 Estate of Testa (Deceased) and Does | to 100, Bepe—_—4— 15 Defendants. MOTION IN LIMINE NO. 13 FOR AN ORDER PRECLUDING EVIDENCE OF 16 OR REFERENCE TO ANY SUBSEQUENT REMEDIAL MEASURES; 17 DECLARATION OF HETAL KOMMES; ORDER [PROPOSED] 18 19 I 20 PLAINTIFF SHOULD NOT BE ALLOWED TO REFER TO ANY 21 SUBSEQUENT REMEDIAL MEASURES MADE TO THE 22 PREMISES WHERE SHE FELL 24 Plaintiff seeks damages from a trip and fall that happened on December 8, 2015, at the he 2s entrance path of Lynn Testa’s (“Testa”) property at 2050 Santa Rena Drive in Palos Verdes, 26 California. Plaintiff claims she tripped on a gap between the stepping stones making up the entry 27 path to the door of the subject premises. The property was being readied for sale after the death 28 of Testa. Parts of the home and the exterior, including the entry path were upgraded as part of -l- DEFENDANT'S MOTION IN LIMINE NO. 13