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  • SHIRLENE GARBUTT VS 99 CENTS ONLY STORES LLC Premise Liability (e.g., dangerous conditions of property, slip/trip and fall, dog attack, etc.) (General Jurisdiction) document preview
  • SHIRLENE GARBUTT VS 99 CENTS ONLY STORES LLC Premise Liability (e.g., dangerous conditions of property, slip/trip and fall, dog attack, etc.) (General Jurisdiction) document preview
						
                                

Preview

jel? John R. DaCorsi, Esq. SBN 44983 PSC Michael M. Hernandez, Esq. SBN 123132 DaCORSI PLACENCIO, P.C. 21031 Ventura Boulevard, Suite 640 Woodland Hills, California 91364-2229 Telephone: (818) 884-6666 Fi Supe Facsimile: (818) 884-8677 Coun’ Attorneys for Defendant 99 CENTS ONLY STORES, LLC Sheri Ay C erk By. \4 =z _ Deputy Raul Sanchez SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT 10 11 SHIRLENE GARBUTT, Case No. BC 540377 Case assigned to Dept. 97 12: Plaintiff, DEFENDANT’S MOTION IN LIMINE #4 13 vs. TO PRECLUDE THE INTRODUCTION OF THE LAC-USC MEDICAL 14 99 CENTS ONLY STORES, LLC, and CENTER/COUNTY OF LOS ANGELES DOES 1 TO 50, INCLUSIVE BILLING WHICH HAS BEEN 15) REDUCED TO ZERO; DECLARATION Defendants. OF COUNSEL; AND ORDER THEREON 16 Complaint Filed: Mar. 24, 2014 17 18 FSC: 10/27/16 Trial: 11/08/16 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: 20 PLEASE TAKE NOTICE THAT Defendant 99 CENTS ONLY STORES, LLC (“Defendant”), erroneously sued as 99 CENTS ONLY STORE, INC. (“Defendant”), before trial and the selection of the jury, will and hereby does move the Court in limine as follows: 23) 1 A ruling and determination that testimony or other evidence regarding the County 24 of Los Angeles billing be excluded as said bill has been reduced to zero; and 25 Directing that Plaintiff, her attorney, and her witnesses shall refrain from 26 mentioning or referring to, directly or indirectly, communicating or disclosing, or 27 attempting to elicit from any witness in the presence or hearing of jurors or 28 1 MIL #4 - PRECLUSION OF LAC-USC MEDICAL CENTER/LA COUNTY BILLING