Motion,Ex Parte: FATIMA ABDUL VS ACCESS SERVICES

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                   KENTON E. MOORE, STATE BAR #143645                                                           FILED
                                                                                                      Super'n: * Court
                   ANDREW L. SMITH, STATE BAR #262418                                                    Cou inty       of Calitornia
                                                                                                                  of tn A.
                   McCUNE & HARBER, LLP
                   515 South Figueroa Street, Suite 1100                                                     SEP 13 2017
                   Los Angeles, California 90071                                                  Sherri Ry Carter, Exquut
                   Telephone: (213) 689-2500                                                       By.
                                                                                                                           ive Ulicer/Clerk
                   Facsimile: (213) 689-2501                                                                                        Ueputy
                                                                                                             Raut Sanchar
                   kmoore@mccuneharber.com and asmith@mccuneharber.com

                   Attorneys for Defendant, ACCESS SERVICES [PUBLIC ENTITY FEE EXEMPT GOVERNMENT CODE §
                   6103]


                                              SUPERIOR COURT OF THE STATE OF CALIFORNIA

                                           FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT

             10

   ove
             11    FATIMA ABDUL,                                             Case No: BC600040
    ae                                                                       [ASSIGNED TO DEPARTMENT 91;
Roe
258 22 12                     Plaintiff,                                     HONORABLE PATRICIA NIETO, FOR ALL
Soe                                                                          PURPOSES]
Seog
  Sos    213       vs.
        oF                                                                       (Complaint filed on November 5, 2015)
      S45 14       ACCESS SERVICES, a local public entity,
                   through LOS ANGELES COUNTY                                    DEFENDANT'S MOTION IN LIMINE NO. 3
             15    CONSOLIDATED TRANSPORTATION                                   TO EXCLUDE IMPROPER AND
                   SERVICES AGENCY, and DOES 1 through                           PREJUDICAL STATEMENTS AT TIME OF
             16    20, inclusive,                                                TRIAL (“REPTILE THEORY”);
                                                                                 DECLARATION OF ANDREW L. SMITH;
             17               Defendants.                                        MEMORANDUM OF POINTS AND
                                                                                 AUTHORITIES
             18
                                                                                 DATE:   October 5, 2017
             19                                                                  TIME: 1:30 p.m.
                                                                                 DEPT.: 91
             20
                                                                                 Trial Date: October 16, 2017
             21                                                                  FSC Date:       October 5, 2017

             22

             23               TO ALL PARTIES AND TO THEIR RESPECTIVE ATTORNEYS OF RECORD:
             24               Defendants ACCESS SERVICES (“Defendant”), will and hereby does move this court in limine
             25    for issuance of the following orders:

             26               1.   An order precluding plaintiff, plaintiff's counsel, or experts from making reference to,
             a
             27                    identifying or introducing at the time of trial any evidence meant to improperly evoke the

             128                   emotions of the jury, for example: (1) calling on the jury to be the conscience of the
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                   23700077                                                                                         Defendant's Motion In Limine No. 3