On April 22, 2015 a
Motion-Secondary
was filed
involving a dispute between
Jimenez Elvia,
and
Caballero Carlos,
Caballero Flora,
for civil
in the District Court of Los Angeles County.
Preview
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Ara O. Seropian, Esq., (State Bar No: 221799)
RAFFALOW, RHOADS, BRETOI
Attorneys at Law
4484 Wilshire Boulevard, Second Floor
Los Angeles, California 90010 Superior Court gf California
(323) 857-7175 ounty of Los Angeles
Attorney for Defendants,
OCT 07 2016
Flora Caballero and Carlos Caballero Sh eri 2 Carter, o tive Officer/Clerk
B Deputy
Our File No.: 15-56456-59 Raut Sanchez
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
10
11
ELVIA SIMENEZ, an Individual, CASE NO: BC579516
12
Plaintiff,
13 OPPOSITION TO PLAINTIFF'S
vs. MOTION IN LIMINE #8 EXCLUDING
14
EVIDENCE OF REFERRAL BY
FLORA CABALLERO, an Individual; CARLOS ATTORNEY TO ANY MEDICAL
15
CABALLERO, an Individual; and DOES 1 to 50, DOCTOR AT TRIAL
Inclusive,, et al.,
16
Date: 10/24/16
Defendants. Time 8:30am.
17
Dept: 97
18 Defendants opposes Plaintiff's Motion in Limine #8 for an order excluding evidence of referral by
19 attorney tc any Medical Doctor at trial because it is relevant to show that the Plaintiff retained an attorney
20 prior to seeking medical attention and also calls into question the credibility of plaintiffs claims along with
21 plaintiff's motive of for seeking medical treatment (financial vs. health). The referral is also relevant as to
22 the bias of the doctor's expert testimony.
23 The treating doctor/chiropractor has an economic interest in the outcome of this trial and his
pe
SD
24he -opinions, whether written or verbal, regarding Plaintiff's medical treatment is tainted to the outcome of this
he
25 trial. The evidence of referral by Plaintiff attorney is also relevant as to Plaintiff's damages and the
RD
<>
-possibility ofacohesion work up between Plaintiffs, their attorney, and their doctor(s) regarding the extent
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27
1
28
OPPOSITION TO PLAINTIFF'S MOTION IN LIMINE EXCLUDING
EVIDENCE OF REFERRAL BY ATTORNEY TO MEDICAL DOCTOR
Document Filed Date
October 07, 2016
Case Filing Date
April 22, 2015
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pO @ @ a‘ Ara O. Seropian, Esq., (State Bar No: 221799) RAFFALOW, RHOADS, BRETOI Attorneys at Law 4484 Wilshire Boulevard, Second Floor Los Angeles, California 90010 Superior Court gf California (323) 857-7175 ounty of Los Angeles Attorney for Defendants, OCT 07 2016 Flora Caballero and Carlos Caballero Sh eri 2 Carter, o tive Officer/Clerk B Deputy Our File No.: 15-56456-59 Raut Sanchez SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES 10 11 ELVIA SIMENEZ, an Individual, CASE NO: BC579516 12 Plaintiff, 13 OPPOSITION TO PLAINTIFF'S vs. MOTION IN LIMINE #8 EXCLUDING 14 EVIDENCE OF REFERRAL BY FLORA CABALLERO, an Individual; CARLOS ATTORNEY TO ANY MEDICAL 15 CABALLERO, an Individual; and DOES 1 to 50, DOCTOR AT TRIAL Inclusive,, et al., 16 Date: 10/24/16 Defendants. Time 8:30am. 17 Dept: 97 18 Defendants opposes Plaintiff's Motion in Limine #8 for an order excluding evidence of referral by 19 attorney tc any Medical Doctor at trial because it is relevant to show that the Plaintiff retained an attorney 20 prior to seeking medical attention and also calls into question the credibility of plaintiffs claims along with 21 plaintiff's motive of for seeking medical treatment (financial vs. health). The referral is also relevant as to 22 the bias of the doctor's expert testimony. 23 The treating doctor/chiropractor has an economic interest in the outcome of this trial and his pe SD 24he -opinions, whether written or verbal, regarding Plaintiff's medical treatment is tainted to the outcome of this he 25 trial. The evidence of referral by Plaintiff attorney is also relevant as to Plaintiff's damages and the RD <> -possibility ofacohesion work up between Plaintiffs, their attorney, and their doctor(s) regarding the extent cn > D 27 1 28 OPPOSITION TO PLAINTIFF'S MOTION IN LIMINE EXCLUDING EVIDENCE OF REFERRAL BY ATTORNEY TO MEDICAL DOCTOR