On July 09, 2014 a
Motion,Ex Parte
was filed
involving a dispute between
Camacho Lester,
Lester Camacho,
P. Paul Aghabala & Associates Inc.,
and
Blue Jay Group Inc.,
Brentwood Holdings Partners Llc,
Kuzenetsky Michael,
Hayes Scott Bonino Ellingson Guslani Simonson & Clause Llp,
for civil
in the District Court of Los Angeles County.
Preview
e e
P. Paul Aghabala, Esq. (SBN: 223585) FILED
etior Court of California
LAW OFFICES OF P. PAUL AGHABALA & ASSOCIATES, I untv of Los Anneles
15315 Magnolia Boulevard, Suite 426
Sherman Oaks, California 91403 NOV 14 2017
Telephone: (818)788-0808 Sherri R. cz executive Office
r/Clerk
Facsimile: (818)788-0809 By.
Deputy
Attorneys for Plaintiff, LESTER CAMACHO
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT
10
11
LESTER CAMACHO CASE NO.: BCS51002
12
Plaintiff,
13 PLAINTIFF, LESTER CAMACHO’S
vs. MOTION IN LIMINE NO. 13 TO
14
EXCLUDE TESTIMONY OF TAMARA
15 BRENTWOOD HOLDINGS PARTNERS, ROCKHOLT, R.N. AS A NON-QUALIFIED
LLC, and DOES 1 to 100, EXPERT OR, IN THE ALTERNATIVE, TO
16 EXCLUDE THE OPINIONS OF TAMI
ROCKHOLT, R.N, BECAUSE THEY
Defendants. LACK EVIDENTIARY VALUE;
17
MEMORANDUM OF POINTS AND
18 AUTHORITIES; DECLARATION OF
PAUL AGHABALA
19
20
21
TO DEFENDANTS BRENTWOOD HOLDINGS PARTNERS, LLC, AND BLUE
22
JAY GROUP, INC. AND THEIR ATTORNEYS OF RECORD:
23
24 PLEASE TAKE NOTICE that Plaintiff, Lester Camacho, respectfully move the Court, by
25 this Motion in Limine No. 13 for an order precluding testimony of Tamara Rockholt, R.N., who
26 Defendants designated as their expert regarding the reasonableness of Plaintiff's medical charges.
27 The motion is brought on grounds that the witness lacks the requisite knowledge, skill,
28 1
ah
MOTION IN LIMINE # 13
hi
oO
al
Document Filed Date
November 14, 2017
Case Filing Date
July 09, 2014
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e e P. Paul Aghabala, Esq. (SBN: 223585) FILED etior Court of California LAW OFFICES OF P. PAUL AGHABALA & ASSOCIATES, I untv of Los Anneles 15315 Magnolia Boulevard, Suite 426 Sherman Oaks, California 91403 NOV 14 2017 Telephone: (818)788-0808 Sherri R. cz executive Office r/Clerk Facsimile: (818)788-0809 By. Deputy Attorneys for Plaintiff, LESTER CAMACHO SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT 10 11 LESTER CAMACHO CASE NO.: BCS51002 12 Plaintiff, 13 PLAINTIFF, LESTER CAMACHO’S vs. MOTION IN LIMINE NO. 13 TO 14 EXCLUDE TESTIMONY OF TAMARA 15 BRENTWOOD HOLDINGS PARTNERS, ROCKHOLT, R.N. AS A NON-QUALIFIED LLC, and DOES 1 to 100, EXPERT OR, IN THE ALTERNATIVE, TO 16 EXCLUDE THE OPINIONS OF TAMI ROCKHOLT, R.N, BECAUSE THEY Defendants. LACK EVIDENTIARY VALUE; 17 MEMORANDUM OF POINTS AND 18 AUTHORITIES; DECLARATION OF PAUL AGHABALA 19 20 21 TO DEFENDANTS BRENTWOOD HOLDINGS PARTNERS, LLC, AND BLUE 22 JAY GROUP, INC. AND THEIR ATTORNEYS OF RECORD: 23 24 PLEASE TAKE NOTICE that Plaintiff, Lester Camacho, respectfully move the Court, by 25 this Motion in Limine No. 13 for an order precluding testimony of Tamara Rockholt, R.N., who 26 Defendants designated as their expert regarding the reasonableness of Plaintiff's medical charges. 27 The motion is brought on grounds that the witness lacks the requisite knowledge, skill, 28 1 ah MOTION IN LIMINE # 13 hi oO al