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.
Preview
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Brown, Brown & Brown
David S. Brown; Bar No. 89438
Joan Benjamin Brown; Bar No. 93572 FILED
Aaron M. Brown; Bar No. 277981 Superior Court of California
23326 Hawthorne Boulevard, Suite 380 Countv of Uns Angeles
Torrance, CA 90505-3725
310-378-3733; fax 310-378-0703 MAY 07 2018
mrtorts@aol.com Sherri R. Ca t Executive Officer/Clerk of Court
By. Deputy
Attorneys for Plaintiff Ran! Sanchec
SUPERIOR COURT OF CALIFORNIA
COUNTY OF LOS ANGELES
10
Marie Underhill, Plaintiff, BC638507, Dept. 4, trial 5-15-18
11
V.
12
Estate of Testa (Deceased) and Does OPPOSITION TO MOTION IN
13 1 to 100, Defendants. LIMINE 3
14
15
16
Plaintiff opposes defendant's motion in limine 3. The motion speculates as to
17
what plaintiff may do in trial with no basis in fact.
18
19 Defendant argues that plaintiff may present her case under the so-called “Reptile
20 Theory.” Defendant provides its own interpretation of the so-called theory and then
21 asks the court to disallow argument under this theory.
22
The motion itself underscores why it is an improper motion in limine. There is no
>
AT
wh,
de specific evidence or even type of evidence addressed.
26) Plaintiff cannot tell what defendant is seeking to preclude. Plaintiff will tailor her
en
26>
oo arguments to the facts and law of this case. Defendant cannot preempt plaintiff's
27
28
OPPOSITION TO MOTION IN LIMINE 3
Document Filed Date
May 07, 2018
Case Filing Date
October 26, 2016
Status
Jury Verdict 05/25/2018
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A f ’ Brown, Brown & Brown David S. Brown; Bar No. 89438 Joan Benjamin Brown; Bar No. 93572 FILED Aaron M. Brown; Bar No. 277981 Superior Court of California 23326 Hawthorne Boulevard, Suite 380 Countv of Uns Angeles Torrance, CA 90505-3725 310-378-3733; fax 310-378-0703 MAY 07 2018 mrtorts@aol.com Sherri R. Ca t Executive Officer/Clerk of Court By. Deputy Attorneys for Plaintiff Ran! Sanchec SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES 10 Marie Underhill, Plaintiff, BC638507, Dept. 4, trial 5-15-18 11 V. 12 Estate of Testa (Deceased) and Does OPPOSITION TO MOTION IN 13 1 to 100, Defendants. LIMINE 3 14 15 16 Plaintiff opposes defendant's motion in limine 3. The motion speculates as to 17 what plaintiff may do in trial with no basis in fact. 18 19 Defendant argues that plaintiff may present her case under the so-called “Reptile 20 Theory.” Defendant provides its own interpretation of the so-called theory and then 21 asks the court to disallow argument under this theory. 22 The motion itself underscores why it is an improper motion in limine. There is no > AT wh, de specific evidence or even type of evidence addressed. 26) Plaintiff cannot tell what defendant is seeking to preclude. Plaintiff will tailor her en 26> oo arguments to the facts and law of this case. Defendant cannot preempt plaintiff's 27 28 OPPOSITION TO MOTION IN LIMINE 3