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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

Brown, Brown & Brown David S. Brown; Bar No. 89438 Joan Benjamin Brown; Bar No. 93572 Aaron M. Brown; Bar No. 277981 FILED rnia 23326 Hawthorne Boulevard, Suite 380 Sup erior Court of Califo Caunty a # Ins Angeles Torrance, CA 90505-3725 310-378-3733; fax 310-378-0703 MAY 08 2018 mrtorts@aol.com Sherri RC: ee Offic er/Clerk of Cpurt jeputy Attorneys for Plaintiff By. Raul Sanchez SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES 10 Marie Underhill, Plaintiff, BC638507, Dept. 4, trial 5-15-18 11 Vv. 12 Estate of Testa (Deceased) and Does PLAINTIFF'S MOTION IN LIMINE 1; 13 1 to 100, Defendants. DECLARATION OF JOAN BENJAMIN BROWN 14 15 16 Plaintiff moves in limine to preclude all testimony, evidence, or argument that 17 plaintiff was a beneficiary of the Estate of Lynn Testa, the defendant in this action. Any 18 such testimony, evidence, or argument would be irrelevant and highly prejudicial. 19 20 Plaintiff Marie Underhill was injured while walking on an unfinished entry 21 walkway. Stones were laid, but the gaps between them had not yet been filled with 22 concrete. The right side of her foot went into a gap between two sections of flagstone and she was thrown forward and landed face down. At the time of plaintiff's fall, the 24. property was owned by the Estate of Lynne Testa. Ms. Testa had died before plaintiff's 25. fall. 27 Plaintiff and the decedent were friends, and plaintiff was a beneficiary of Ms. 28 PLAINTIFF'S MOTION JN LIMINE 1