On October 19, 2016 a
Party Discovery
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
a
Superior E,
‘Ounty of
Loe. fa
lta
KENTON E. MOORE, STATE BAR #143645
BENSON E. GARRETT, STATE BAR #237134
McCUNE & HARBER, LLP Sherr} APR 04 201
515 South Figueroa Street, Suite 1100 By
icer/Clert|
Los Angeles, California 90071
Telephone: (213) 689-2500 / Facsimile: (213) 689-2501 n Gomez Deputy
kmoore@mccuneharber.com and bgarrett@mecuneharber.com
Attomeys for Defendant and Cross-Complainant, CITY OF REDONDO BEACH [FEE EXEMPT
PUBLIC ENTITY, GOVERNMENT CODE § 6103]
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT
10
ges 11 TANAZ ZAMANI, an individual, Case No: BC637727
Bo! [ASSIGNED TO DEPARTMENT 98;
RS) 285 12
Plaintiff, HONORABLE HOLLY J. FUJIE FOR ALL
Shae PURPOSES
Seog
B95 2 13 Vv. (Complaint filed on October 19, 2016)
BSe6R
95 14 CITY OF REDONDO BEACH; GILBERT DATE: July 5, 2018
COTA; ROSA COTA and DOES 1-20, TIME: 10:00 a.m.
15 Inclusive, DEPT.: 98
16 Defendants. MOTION IN LIMINE NO. 2 OF DEFENDANT
CITY OF REDONDO BEACH TO EXCLUDE
17 EXPERT OPINIONS NOT EXPRESSED AT
AND ALL RELATED CROSS ACTIONS. DEPOSITION; MEMORANDUM OF POINTS
18 AND AUTHORITIES; DECLARATION OF
BENSON E. GARRETT
19
Trial Date: July 19, 2018
20 FSC Date: July 5, 2018
21
22 TO ALL PARTIES AND THEIR RESPECTIVE ATTORNEYS OF RECORD:
23 PLEASE TAKE NOTICE that on July 5, 2018 at 8:30 a.m. or as soon thereafter as counsel
we
24 may be heard in Department 98 of the above-entitled Court located at 111 North Hill St., Los Angeles,
= 25 California, Defendant and Cross-Complainant, CITY OF REDONDO BEACH will and hereby does
26 move the court, in limine, for issuance of the following orders:
27 1. Precluding plaintiff from eliciting expert opinions not expressed at deposition;
28 2. An order precluding plaintiff, plaintiff's counsel, or experts from making reference to,
-l-
11200032 Motion In Limine #2
JAWPDOCs\Zamani, T v. City of Redondo Beach\Pld\Trial\MILs\MIL #2 (experts).docx
Document Filed Date
April 04, 2018
Case Filing Date
October 19, 2016
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a Superior E, ‘Ounty of Loe. fa lta KENTON E. MOORE, STATE BAR #143645 BENSON E. GARRETT, STATE BAR #237134 McCUNE & HARBER, LLP Sherr} APR 04 201 515 South Figueroa Street, Suite 1100 By icer/Clert| Los Angeles, California 90071 Telephone: (213) 689-2500 / Facsimile: (213) 689-2501 n Gomez Deputy kmoore@mccuneharber.com and bgarrett@mecuneharber.com Attomeys for Defendant and Cross-Complainant, CITY OF REDONDO BEACH [FEE EXEMPT PUBLIC ENTITY, GOVERNMENT CODE § 6103] SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT 10 ges 11 TANAZ ZAMANI, an individual, Case No: BC637727 Bo! [ASSIGNED TO DEPARTMENT 98; RS) 285 12 Plaintiff, HONORABLE HOLLY J. FUJIE FOR ALL Shae PURPOSES Seog B95 2 13 Vv. (Complaint filed on October 19, 2016) BSe6R 95 14 CITY OF REDONDO BEACH; GILBERT DATE: July 5, 2018 COTA; ROSA COTA and DOES 1-20, TIME: 10:00 a.m. 15 Inclusive, DEPT.: 98 16 Defendants. MOTION IN LIMINE NO. 2 OF DEFENDANT CITY OF REDONDO BEACH TO EXCLUDE 17 EXPERT OPINIONS NOT EXPRESSED AT AND ALL RELATED CROSS ACTIONS. DEPOSITION; MEMORANDUM OF POINTS 18 AND AUTHORITIES; DECLARATION OF BENSON E. GARRETT 19 Trial Date: July 19, 2018 20 FSC Date: July 5, 2018 21 22 TO ALL PARTIES AND THEIR RESPECTIVE ATTORNEYS OF RECORD: 23 PLEASE TAKE NOTICE that on July 5, 2018 at 8:30 a.m. or as soon thereafter as counsel we 24 may be heard in Department 98 of the above-entitled Court located at 111 North Hill St., Los Angeles, = 25 California, Defendant and Cross-Complainant, CITY OF REDONDO BEACH will and hereby does 26 move the court, in limine, for issuance of the following orders: 27 1. Precluding plaintiff from eliciting expert opinions not expressed at deposition; 28 2. An order precluding plaintiff, plaintiff's counsel, or experts from making reference to, -l- 11200032 Motion In Limine #2 JAWPDOCs\Zamani, T v. City of Redondo Beach\Pld\Trial\MILs\MIL #2 (experts).docx