Motion,Ex Parte: SHANNON GRIFFITH VS JESSICA WAGSTAFF

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                                ORIGINAL
           ROBERT J. ROMERO (SBN 136539)                                                     FILED
           BRADLEY M. ZAMCZYK (SBN 151753)                                          Superb!'Court Of California
           CASEY A. HATTON (SBN 246081)                                                 County Of Lot Angeles
           HINSHAW & CULBERTSON LIT
           One California Street, 18th Floor                                            FEB 1 5 2018
           San Francisco, CA 94111
           Telephone:     415-362-6000                                         Sherri R. Carter, Ha cfive Gem/Clerk
           Facsimile:     415-834-9070                                                              lit v, ,
                                                                                BY-11°Ar ___________le ?tit eaten
                                                                                                   __________4 De l ) M Y


           Attorneys for Defendant
           JESSICA WAGSTAFF



                               SUPERIOR COURT OF THE STATE OF CALIFORNIA

                          FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT



           SHANNON GRIFFITH,                                         Case No. BC 609667

                           Plaintiff,                                MOTION IN LIMINE NO. 3

                   vs.                                               DEFENDANT JESSICA WAGSTAFF'S
                                                                     MOTION IN LIMINE NO. 3 TO
           JESSICA WAGSTAFF, DOES 1 TO 10,                           EXCLUDE ANY.AND ALL EVIDENCE,
                                                                     TESTIMONY AND ARGUMENT THAT
                           Defendants.                               PLAINTIFF IS AN "EGGSHELL
                                                                     PLAINTIFF"

                                                                     Date: March 26, 2018
                                                                     Time: 8:30 a.m.
                                                                     Dept.: 97

                                                                     Complaint Filed: February 9, 2016
L -J                                                                 Trial Date: March 26, 2018

                   TO PLAINTIFFS AND THEIR ATTORNEYS OF RECORD:

                   PLEASE TAKE NOTICE that on March 26,2018 at 8:30 a.m. in Department 97 of the

           above entitled court, Defendant Jessica Wagstaff ("Wagstaff') will move this court in limine for an

   r•.,)   order excluding any and all evidence, testimony and argument that plaintiff Shannon Griffith
    ..„

           ("Griffith" or "Plaintiff') is an "eggshell plaintiff," "thin skull plaintiff' or "eggshell skull plaintiff."

           This motion is being made pursuant to California Evidence Code sections 350 and 352 on the

           grounds that argument related to Plaintiff as an "eggshell skull plaintiff' is irrelevant, immaterial,

           confusing, and will create a substantial danger of undue prejudice to Defendant. As such, Defendant

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                DEFENDANT'S MOTION IN LIMINE NO. 3 TO EXCLUDE ANY AND ALL EVIDENCE, TESTIMONY ANg
                              ARGUMENT THAT PLAINTIFF IS AN "EGGSHELL PLAINTIFF" — Case No. BC 6096671