On August 11, 2016 a
Motion,Ex Parte
was filed
involving a dispute between
Mestre Rudy,
and
Access Services,
Diaz Judith,
Global Paratransit Inc.,
Los Angeles County Consolidated Transpor-,
for civil
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 08/01/2019 03:04 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,Deputy Clerk
1 KENTON E. MOORE, STATE BAR #143645
JULIAN S. SMITH, STATE BAR #309241
2 McCUNE & HARBER, LLP
515 South Figueroa Street, Suite 1100
3 Los Angeles, California 90071
Telephone: (213) 689-2500 / Facsimile: (213) 689-2501
4 kmoore@mccuneharber.com and jsmith@mccuneharber.com
5 Attorneys for Defendants, ACCESS SERVICES, LOS ANGELES COUNTY CONSOLIDATED
TRANSPORTATION SERVICES AGENCY, AND GLOBAL PARATRANSIT, INC.
6
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF LOS ANGELES – SPRING STREET COURTHOUSE
10
11 Rudy Mestre, Case No: BC630538
MCCUNE & HARBER, LLP
515 SOUTH FIGUEROA ST.
LOS ANGELES, CA 90071
Assigned to Honorable Marc D. Gross; Department 3
Fax (213) 689-2501
12
(213) 689-2500
Plaintiff, (Complaint filed on August 11, 2016)
13 v. DATE: August 5, 2019
TIME: 10:00 a.m.
14 Access Services, Judith Diaz; Los Angeles DEPT.: 3
County Consolidated Transportation Services
15 Agency; Global Paratransit, Inc.; and Does 1 to MOTION IN LIMINE NO. 3 BY
100, Inclusive, DEFENDANTS TO LIMIT PLAINTIFF’S
16 CLAIMED MEDICAL SPECIAL DAMAGES
Defendants. TO THOSE ACTUALLY PAID ;
17 MEMORANDUM OF POINTS AND
AUTHORITIES; DECLARATION OF JULIAN
18 SMITH
19 Trial Date: August 19, 2019
FSC Date: August 5, 2019
20
21 Defendants ACCESS SERVICES, JUDITH DIAZ, LOS ANGELES COUNTY
22 CONSOLIDATED TRANSPORTATION SERVICES AGENCY, and GLOBAL PARATRANSIT,
23 INC. will and hereby does move the court in limine for issuance of the following orders:
24 1. Limiting evidence of plaintiff’s economic losses to the amounts actually expended for
25 the plaintiff’s medical care by any third-party payor, plaintiff’s private insurer and the plaintiff himself;
26 2. An order precluding plaintiff, plaintiff’s counsel, or experts from making reference to,
27 identifying or introducing at the time of trial any other such evidence or testimony concerning
28 plaintiff’s economic losses in all of plaintiff’s produced medical records;
-1- Page 1
J:\WPDOCs\Mestre, Rudy v. Access Services\Trial\MILs\MIL #3 (Howell).docx 23700112
Document Filed Date
August 01, 2019
Case Filing Date
August 11, 2016
Status
Request for Dismissal - Before Trial not following ADR or more than 60 days since ADR 02/10/2020
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Electronically FILED by Superior Court of California, County of Los Angeles on 08/01/2019 03:04 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,Deputy Clerk 1 KENTON E. MOORE, STATE BAR #143645 JULIAN S. SMITH, STATE BAR #309241 2 McCUNE & HARBER, LLP 515 South Figueroa Street, Suite 1100 3 Los Angeles, California 90071 Telephone: (213) 689-2500 / Facsimile: (213) 689-2501 4 kmoore@mccuneharber.com and jsmith@mccuneharber.com 5 Attorneys for Defendants, ACCESS SERVICES, LOS ANGELES COUNTY CONSOLIDATED TRANSPORTATION SERVICES AGENCY, AND GLOBAL PARATRANSIT, INC. 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES – SPRING STREET COURTHOUSE 10 11 Rudy Mestre, Case No: BC630538 MCCUNE & HARBER, LLP 515 SOUTH FIGUEROA ST. LOS ANGELES, CA 90071 Assigned to Honorable Marc D. Gross; Department 3 Fax (213) 689-2501 12 (213) 689-2500 Plaintiff, (Complaint filed on August 11, 2016) 13 v. DATE: August 5, 2019 TIME: 10:00 a.m. 14 Access Services, Judith Diaz; Los Angeles DEPT.: 3 County Consolidated Transportation Services 15 Agency; Global Paratransit, Inc.; and Does 1 to MOTION IN LIMINE NO. 3 BY 100, Inclusive, DEFENDANTS TO LIMIT PLAINTIFF’S 16 CLAIMED MEDICAL SPECIAL DAMAGES Defendants. TO THOSE ACTUALLY PAID ; 17 MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF JULIAN 18 SMITH 19 Trial Date: August 19, 2019 FSC Date: August 5, 2019 20 21 Defendants ACCESS SERVICES, JUDITH DIAZ, LOS ANGELES COUNTY 22 CONSOLIDATED TRANSPORTATION SERVICES AGENCY, and GLOBAL PARATRANSIT, 23 INC. will and hereby does move the court in limine for issuance of the following orders: 24 1. Limiting evidence of plaintiff’s economic losses to the amounts actually expended for 25 the plaintiff’s medical care by any third-party payor, plaintiff’s private insurer and the plaintiff himself; 26 2. An order precluding plaintiff, plaintiff’s counsel, or experts from making reference to, 27 identifying or introducing at the time of trial any other such evidence or testimony concerning 28 plaintiff’s economic losses in all of plaintiff’s produced medical records; -1- Page 1 J:\WPDOCs\Mestre, Rudy v. Access Services\Trial\MILs\MIL #3 (Howell).docx 23700112