On October 19, 2016 a
Motion,Ex Parte
was filed
involving a dispute between
Zamani Tanaz,
and
Arakelian Enterprises Inc. Dba Athens,
City Of Redondo Beach,
Cota Gilbert,
Cota Rosa,
Emmerson John,
Ghavami Ashkan,
Schaye Gordon,
Soma Medical Group Inc.,
Wu David,
for civil
in the District Court of Los Angeles County.
Preview
®
KENTON E. MOORE, STATE BAR #143645
JULIAN S. SMITH, STATE BAR #309241 7
McCUNE & HARBER, LLP Superior Court of
515 South Figueroa Street, Suite 1100 Peete California
Los Angeles, California 90071 w7 Aenalag
Telephone: (213) 689-2500 / Facsimile: (213) 689-2501
kmoore@mccuneharber.com and jsmith@mccuneharber.com
sherri i, cg,
OCT 02 2018
ey caste ve suscer
EAGH Se
iierk of Cour
Attorneys for Defendant and Cross-Complainant, CITY OF REDONDO.BE ¢
[FEE EXEMPT PUBLIC ENTITY, GOVERNMENT CODE § 6103] *Seputy
oul Sonches
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT
10 N
NN
vz
11 TANAZ ZAMANI, an individual, Case No: BC637727
2 Bae [Assigned to Hon. Yolanda Orozco — Dept 7]
Rez
a3 212
a8
RS Plaintiff, (Complaint filed on October 19, 2016)
L3hn
Ss
3Sg6
213 Vv. DATE: October 3, 2018
TIME: 10:00 a.m.
59814 CITY OF REDONDO BEACH; GILBERT DEPT.:
71
COTA; ROSA COTA and DOES 1-20,
15 Inclusive, MOTION IN LIMINE NO. 11 BY
DEFENDANT CITY OF REDONDO BEACH
16 Defendants. TO EXCLUDE EXPERT OPINION BY
PLAINTIFF THAT THE SUBJECT AREA
17 WAS “DANGEROUS” OR “UNSAFE,” AND
AND ALL RELATED CROSS ACTIONS. TO EXCLUDE LEGAL CONCLUSION OF
18 PLAINTIFF’S EXPERTS THAT THE
ACCIDENT OCCURRED AS A RESULT OF
19 “NEGLIGENCE; MEMORANDUM OF
POINTS AND AUTHORITIES;
20 DECLARATION OF JULIAN SMITH
21 Trial Date: October 18, 2018
FSC Date: October 03, 2018
22
23
24 TO ALL PARTIES AND THEIR RESPECTIVE ATTORNEYS OF RECORD:
25 PLEASE TAKE NOTICE that on October 3, 2018 at 10:00 a.m. or as soon thereafter as
26 counsel may be heard in Department 7 of the above-entitled Court located at 312 N Spring Street, Los
we
cp
fo,
> 228 -1-
JAWPDOCSs\Zamani, T v. City of Redondo Beach\Pid\Trial\MILs\MIL #11 (exclude opinions that the area is “dangerous” or “unsafe”).docx. 11200032
Motion In Limine #11
Document Filed Date
October 02, 2018
Case Filing Date
October 19, 2016
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® KENTON E. MOORE, STATE BAR #143645 JULIAN S. SMITH, STATE BAR #309241 7 McCUNE & HARBER, LLP Superior Court of 515 South Figueroa Street, Suite 1100 Peete California Los Angeles, California 90071 w7 Aenalag Telephone: (213) 689-2500 / Facsimile: (213) 689-2501 kmoore@mccuneharber.com and jsmith@mccuneharber.com sherri i, cg, OCT 02 2018 ey caste ve suscer EAGH Se iierk of Cour Attorneys for Defendant and Cross-Complainant, CITY OF REDONDO.BE ¢ [FEE EXEMPT PUBLIC ENTITY, GOVERNMENT CODE § 6103] *Seputy oul Sonches SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT 10 N NN vz 11 TANAZ ZAMANI, an individual, Case No: BC637727 2 Bae [Assigned to Hon. Yolanda Orozco — Dept 7] Rez a3 212 a8 RS Plaintiff, (Complaint filed on October 19, 2016) L3hn Ss 3Sg6 213 Vv. DATE: October 3, 2018 TIME: 10:00 a.m. 59814 CITY OF REDONDO BEACH; GILBERT DEPT.: 71 COTA; ROSA COTA and DOES 1-20, 15 Inclusive, MOTION IN LIMINE NO. 11 BY DEFENDANT CITY OF REDONDO BEACH 16 Defendants. TO EXCLUDE EXPERT OPINION BY PLAINTIFF THAT THE SUBJECT AREA 17 WAS “DANGEROUS” OR “UNSAFE,” AND AND ALL RELATED CROSS ACTIONS. TO EXCLUDE LEGAL CONCLUSION OF 18 PLAINTIFF’S EXPERTS THAT THE ACCIDENT OCCURRED AS A RESULT OF 19 “NEGLIGENCE; MEMORANDUM OF POINTS AND AUTHORITIES; 20 DECLARATION OF JULIAN SMITH 21 Trial Date: October 18, 2018 FSC Date: October 03, 2018 22 23 24 TO ALL PARTIES AND THEIR RESPECTIVE ATTORNEYS OF RECORD: 25 PLEASE TAKE NOTICE that on October 3, 2018 at 10:00 a.m. or as soon thereafter as 26 counsel may be heard in Department 7 of the above-entitled Court located at 312 N Spring Street, Los we cp fo, > 228 -1- JAWPDOCSs\Zamani, T v. City of Redondo Beach\Pid\Trial\MILs\MIL #11 (exclude opinions that the area is “dangerous” or “unsafe”).docx. 11200032 Motion In Limine #11