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
Brown, Brown & Brown
David S. Brown; Bar No. 89438 FILED
Superior Court of California
Joan Benjamin Brown; Bar No. 93572 Countv af Los Angeles
Aaron M. Brown; Bar No. 277981
23326 Hawthorne Boulevard, Suite 380 MAY 07 2018
Torrance, CA 90505-3725
<
Sherri R. Ca ter, Executive Officer/Clerk of Ceurt
310-378-3733; fax 310-378-0703
mrtorts@aol.com By. +Deputy
Raul Sanchez
Attorneys for Plaintiff
SUPERIOR COURT OF CALIFORNIA
COUNTY OF LOS ANGELES
10
11
Marie Underhill, Plaintiff, BC638507, Dept. 4, trial 5-15-18
Vv.
12
Estate of Testa (Deceased) and Does OPPOSITION TO MOTION /N
13 1 to 100, Defendants. LIMINE 11
14
15
16
Plaintiff opposes motion in limine 11, to preclude plaintiff's liability expert Richard
17
Grossman from offering any human factors testimony.
18
19 Richard Grossman is a professional engineer licensed by the State of California
20 in the separate disciplines of Mechanical Engineering and Safety Engineering. The
21 discipline of Safety Engineering includes analyzing structures and situations from the
22
point of view of safety. It also includes physics and physical analysis.
3wT
24 While Mr. Grossman is not a human factors expert, he is a safety expert and he
60
should be permitted to testify as to safety. There may be testimony that could involve
Re
2
26
oo either type of expert, but that is not grounds for the exclusion of Mr. Grossman's
27
testimony.
28
In the event there is any question regarding Mr. Grossman’s qualifications, the
OPPOSITION TO MOTION IN LIMINE 11
4
Document Filed Date
May 07, 2018
Case Filing Date
October 26, 2016
Status
Jury Verdict 05/25/2018
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Brown, Brown & Brown David S. Brown; Bar No. 89438 FILED Superior Court of California Joan Benjamin Brown; Bar No. 93572 Countv af Los Angeles Aaron M. Brown; Bar No. 277981 23326 Hawthorne Boulevard, Suite 380 MAY 07 2018 Torrance, CA 90505-3725 < Sherri R. Ca ter, Executive Officer/Clerk of Ceurt 310-378-3733; fax 310-378-0703 mrtorts@aol.com By. +Deputy Raul Sanchez Attorneys for Plaintiff SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES 10 11 Marie Underhill, Plaintiff, BC638507, Dept. 4, trial 5-15-18 Vv. 12 Estate of Testa (Deceased) and Does OPPOSITION TO MOTION /N 13 1 to 100, Defendants. LIMINE 11 14 15 16 Plaintiff opposes motion in limine 11, to preclude plaintiff's liability expert Richard 17 Grossman from offering any human factors testimony. 18 19 Richard Grossman is a professional engineer licensed by the State of California 20 in the separate disciplines of Mechanical Engineering and Safety Engineering. The 21 discipline of Safety Engineering includes analyzing structures and situations from the 22 point of view of safety. It also includes physics and physical analysis. 3wT 24 While Mr. Grossman is not a human factors expert, he is a safety expert and he 60 should be permitted to testify as to safety. There may be testimony that could involve Re 2 26 oo either type of expert, but that is not grounds for the exclusion of Mr. Grossman's 27 testimony. 28 In the event there is any question regarding Mr. Grossman’s qualifications, the OPPOSITION TO MOTION IN LIMINE 11 4