On May 22, 2015 a
Motion,Ex Parte
was filed
involving a dispute between
Garcia Candice,
Saenz Gerardo,
and
Corale Perla Lazaro Mercado,
L C K Trucking Inc.,
Oropeza Victor Manuel,
for civil
in the District Court of Los Angeles County.
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CHAIN | COHN | STILES
Neil K. Gehlawat, Esq. (SBN 289388)
1731 Chester Avenue Electronically
Bakersfield, CA 93301
Telephone: (661) 323-4000 * FILED
by Superior Court of Califormia
Facsimile: (661) 324-1352 County of Los Angeles on
ngehlawat@chainlaw.com
01/30/18
Sheni R. Carter, Ex ecutive Offic ert lerk
Attorneys for Plaintiffs
Deputy
"Ghroe Hidalgo
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
9 CENTRAL DISTRICT - UNLIMITED CIVIL
10
11 CANDICE GARCIA; GERARDO SAENZ, CASE NO. BC582701
12 Plaintiffs, PLAINTIFFS’ MOTION IN LIMINE NO. 4
TO PRECLUDE DEFENDANTS’
13 V. EXPERT, ERIC DEYERL, P.E., FROM.
14
BASING CAUSATION OPINIONS ON
LCK TRUCKING, INC.; PERLA FATIGUE OR DISTRACTION
15 LAZARO MERCADO CORALE; VICTOR
MANUEL OROPEZA; and DOES 1 TO 50, DATE: September 8, 2017
16 inclusive, TIME: 10:00 a.m.
DEPT.: 91
17 Defendants.
18 TRIAL DATE: September 18, 2017
19 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD HEREIN:
20 PLEASE TAKE NOTICE that on September 8, 2017, in Department 91 of the above-
21 entitled court, located at 111 North Hill Street, Los Angeles, California, Plaintiffs, CANDICE
22
GARCIA and GERARDO SAENZ (“Plaintiffs”), will move this court for an issuance of the
23
following orders in limine:
24
An order precluding Defendants’ expert witness, Eric Deyerl, P.E., from using fatigue or
25
distraction as the basis for his opinion that Plaintiff Saenz turned his vehicle into the tractor/trailer
26
27 at the time of the subject incident; and
a 28 1) An order requiring the attorneys for all parties to instruct their witnesses of the
g JAIN | COHN | STILES. =e
1731 CHESTER AVENUE.
BAKERSFIELD, CA0330% PLAINTIFFS’ MOTION IN LIMINE NO. 4 TO PRECLUDE DEFENDANTS’ EXPERT, ERIC DEYERL, P.E.,
iC (881) 323-4000
FROM BASING CAUSATION OPINIONS ON FATIGUE OR DISTRACTION
Ww
Document Filed Date
January 30, 2018
Case Filing Date
May 22, 2015
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CHAIN | COHN | STILES Neil K. Gehlawat, Esq. (SBN 289388) 1731 Chester Avenue Electronically Bakersfield, CA 93301 Telephone: (661) 323-4000 * FILED by Superior Court of Califormia Facsimile: (661) 324-1352 County of Los Angeles on ngehlawat@chainlaw.com 01/30/18 Sheni R. Carter, Ex ecutive Offic ert lerk Attorneys for Plaintiffs Deputy "Ghroe Hidalgo SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES 9 CENTRAL DISTRICT - UNLIMITED CIVIL 10 11 CANDICE GARCIA; GERARDO SAENZ, CASE NO. BC582701 12 Plaintiffs, PLAINTIFFS’ MOTION IN LIMINE NO. 4 TO PRECLUDE DEFENDANTS’ 13 V. EXPERT, ERIC DEYERL, P.E., FROM. 14 BASING CAUSATION OPINIONS ON LCK TRUCKING, INC.; PERLA FATIGUE OR DISTRACTION 15 LAZARO MERCADO CORALE; VICTOR MANUEL OROPEZA; and DOES 1 TO 50, DATE: September 8, 2017 16 inclusive, TIME: 10:00 a.m. DEPT.: 91 17 Defendants. 18 TRIAL DATE: September 18, 2017 19 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD HEREIN: 20 PLEASE TAKE NOTICE that on September 8, 2017, in Department 91 of the above- 21 entitled court, located at 111 North Hill Street, Los Angeles, California, Plaintiffs, CANDICE 22 GARCIA and GERARDO SAENZ (“Plaintiffs”), will move this court for an issuance of the 23 following orders in limine: 24 An order precluding Defendants’ expert witness, Eric Deyerl, P.E., from using fatigue or 25 distraction as the basis for his opinion that Plaintiff Saenz turned his vehicle into the tractor/trailer 26 27 at the time of the subject incident; and a 28 1) An order requiring the attorneys for all parties to instruct their witnesses of the g JAIN | COHN | STILES. =e 1731 CHESTER AVENUE. BAKERSFIELD, CA0330% PLAINTIFFS’ MOTION IN LIMINE NO. 4 TO PRECLUDE DEFENDANTS’ EXPERT, ERIC DEYERL, P.E., iC (881) 323-4000 FROM BASING CAUSATION OPINIONS ON FATIGUE OR DISTRACTION Ww