On March 13, 2015 a
Motion,Ex Parte
was filed
involving a dispute between
Orange Aero Ltd,
and
Avfi-1 Llc,
for Contractual Fraud (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
@
Stephen G. Zimmerman SBN 235698
2914 E Katella Ave. Suite 200 FILED
Orange, CA 92867 Superior Court of California
ounty of Los Angeles
Tel. (714) 758-5301
Fax (714) 464-2280 SEP 23 2016
Counsel for defendants: f ve Otic Clark
Sherr A Carter, Exqcuti
AVFI-1, AAC, CAM, and Craig Garrick _-| Deputy
Raui Sanchoz
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES
(Unlimited)
10 Orange Aero, Ltd; Case No.: BC575195
i Hon. William Fahey Presiding
Plaintiff,
12 DEFENDANTS’ MOTION JN LIMINE NO. 2
vs. TO EXCLUDE PAROL EVIDENCE
13
AVFI-1, LLC and DOES 1-20, inclusive. FSC: October 19, 2016
14
Time: 9:30 a.m.
15 Defendants. Dept. 69
16 Trial Date: October 31, 201 Y FAX
17
18
19
Defendants AVFI-1, LLC, AAC, LLC, CAM, LLC and Craig Garrick respectfully move
20
in limine pursuant to Code of Civil Procedure § 1856 and Civil Code § 1625 and Evid. Code
21
§§210, 350 and 352 for an order excluding parol evidence. Defendants intend to introduce the
22
Engine Purchase Agreement, dated March 20, 2013 and the Amendment to Engine Purchase
23
Agreement, dated April 25, 2013. A true and correct copy of Exhibit A to the Complaint, The
24
Engine Purchase Agreement and Amendment are attached hereto as Exhibit A. Defendants
Lo 25
believe that plaintiff will attempt to introduce extrinsic evidence and expert testimony to show
mo 26
what the contracting parties intended drafting the Agreement and Amendment, notwithstanding
27
the plain meaning of each contract. The Court should preclude the introduction of this improper
28
parol evidence. -l-
Defendants’ Motion Jn Limine No. 2 to Exclude Parol Evidence
Document Filed Date
September 23, 2016
Case Filing Date
March 13, 2015
Category
Contractual Fraud (General Jurisdiction)
Status
Court-Ordered Dismissal - Other (Other) 10/19/2016
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@ Stephen G. Zimmerman SBN 235698 2914 E Katella Ave. Suite 200 FILED Orange, CA 92867 Superior Court of California ounty of Los Angeles Tel. (714) 758-5301 Fax (714) 464-2280 SEP 23 2016 Counsel for defendants: f ve Otic Clark Sherr A Carter, Exqcuti AVFI-1, AAC, CAM, and Craig Garrick _-| Deputy Raui Sanchoz SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES (Unlimited) 10 Orange Aero, Ltd; Case No.: BC575195 i Hon. William Fahey Presiding Plaintiff, 12 DEFENDANTS’ MOTION JN LIMINE NO. 2 vs. TO EXCLUDE PAROL EVIDENCE 13 AVFI-1, LLC and DOES 1-20, inclusive. FSC: October 19, 2016 14 Time: 9:30 a.m. 15 Defendants. Dept. 69 16 Trial Date: October 31, 201 Y FAX 17 18 19 Defendants AVFI-1, LLC, AAC, LLC, CAM, LLC and Craig Garrick respectfully move 20 in limine pursuant to Code of Civil Procedure § 1856 and Civil Code § 1625 and Evid. Code 21 §§210, 350 and 352 for an order excluding parol evidence. Defendants intend to introduce the 22 Engine Purchase Agreement, dated March 20, 2013 and the Amendment to Engine Purchase 23 Agreement, dated April 25, 2013. A true and correct copy of Exhibit A to the Complaint, The 24 Engine Purchase Agreement and Amendment are attached hereto as Exhibit A. Defendants Lo 25 believe that plaintiff will attempt to introduce extrinsic evidence and expert testimony to show mo 26 what the contracting parties intended drafting the Agreement and Amendment, notwithstanding 27 the plain meaning of each contract. The Court should preclude the introduction of this improper 28 parol evidence. -l- Defendants’ Motion Jn Limine No. 2 to Exclude Parol Evidence