On August 09, 2014 a
Motion in Limine - MOTION IN LIMINE NO. 3 TO PRECLUDE EVIDENCE OF DISCOVERY SANCTIONS AGAINST BALDWIN PARK UNIFIED SCHOOL DISTRICT
was filed
involving a dispute between
Schmittle Juanita Denise,
and
Baldwin Park Unified School District,
Cazorla Sergio,
for civil
in the District Court of Los Angeles County.
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Electronically FILED by Superior Court of California, County of Los Angeles on 07/31/2019 05:39 PM Sherri R. Carter, Executive Officer/Clerk of Court, by R. Sanchez,Deputy Clerk
[Exempt From Filing Fee
Government Code § 6103]
1 MUSICK, PEELER & GARRETT LLP
624 South Grand Avenue, Suite 2000
2 Los Angeles, California 90017-3383
Telephone: (213) 629-7600
3 Facsimile: (213)624-1376
4 Kristine E. Kwong (State Bar No. 160944)
k. kwong@musickpeeler. com
5 Citadelle B. Priagula (State Bar No. 272266)
c.priagula@musickpeeler. com
6
Attorneys for Defendant Baldwin Park Unified School District
7
SUPERIOR COURT OF THE STATE OF CALIFORNIA
8
COUNTY OF LOS ANGELES, CENTRAL DISTRICT
9
10
JUANITA DENISE SCHMITTLE, CASE No. BC595422
11 [Consolidated with Case No. BC685422]
Plaintiff,
12 MOTION IN LIMINE NO. 3
vs.
13 DEFENDANT BALDWIN PARK UNIFIED
BALDWIN PARK UNIFIED SCHOOL SCHOOL DISTRICT’S MOTION IN
14 DISTRICT, SERGIO CAZORLA, an LIMINE NO. 3 TO PRECLUDE
individual, and DOES 1 through 10, inclusive. EVIDENCE OF DISCOVERY
15 SANCTIONS AGAINST BALDWIN PARK
Defendants. UNIFIED SCHOOL DISTRICT;
16 DECLARATION OF CITADELLE B.
PRIAGULA
17
[Filed concurrently with [Proposed] Order]
18
Date: August 22, 2019
19 Time: 9:30 A.M.
Dept: 50
20
Assigned for All Purposes to:
21 Hon. Teresa A. Beaudet, Dept. 50
22 Action Filed: December 4, 2017
Trial Date: September 4, 2019
23 Final Status Conf: August 22. 2019
24
TO ALL PARTIES HEREIN AND TO THEIR RESPECTIVE ATTORNEYS OF
25
RECORD:
26
Defendant BALDWIN PARK UNIFIED SCHOOL DISTRICT (the “District”) hereby
27
moves the Court, in limine, for an Order to preclude Plaintiff, Plaintiffs counsel, and Plaintiffs
28
MUSICK, PEELER
& GARRETT LLP 1168669.1
MOTION IN LIMINE NO. 3
Document Filed Date
July 31, 2019
Case Filing Date
August 09, 2014
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Electronically FILED by Superior Court of California, County of Los Angeles on 07/31/2019 05:39 PM Sherri R. Carter, Executive Officer/Clerk of Court, by R. Sanchez,Deputy Clerk [Exempt From Filing Fee Government Code § 6103] 1 MUSICK, PEELER & GARRETT LLP 624 South Grand Avenue, Suite 2000 2 Los Angeles, California 90017-3383 Telephone: (213) 629-7600 3 Facsimile: (213)624-1376 4 Kristine E. Kwong (State Bar No. 160944) k. kwong@musickpeeler. com 5 Citadelle B. Priagula (State Bar No. 272266) c.priagula@musickpeeler. com 6 Attorneys for Defendant Baldwin Park Unified School District 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 COUNTY OF LOS ANGELES, CENTRAL DISTRICT 9 10 JUANITA DENISE SCHMITTLE, CASE No. BC595422 11 [Consolidated with Case No. BC685422] Plaintiff, 12 MOTION IN LIMINE NO. 3 vs. 13 DEFENDANT BALDWIN PARK UNIFIED BALDWIN PARK UNIFIED SCHOOL SCHOOL DISTRICT’S MOTION IN 14 DISTRICT, SERGIO CAZORLA, an LIMINE NO. 3 TO PRECLUDE individual, and DOES 1 through 10, inclusive. EVIDENCE OF DISCOVERY 15 SANCTIONS AGAINST BALDWIN PARK Defendants. UNIFIED SCHOOL DISTRICT; 16 DECLARATION OF CITADELLE B. PRIAGULA 17 [Filed concurrently with [Proposed] Order] 18 Date: August 22, 2019 19 Time: 9:30 A.M. Dept: 50 20 Assigned for All Purposes to: 21 Hon. Teresa A. Beaudet, Dept. 50 22 Action Filed: December 4, 2017 Trial Date: September 4, 2019 23 Final Status Conf: August 22. 2019 24 TO ALL PARTIES HEREIN AND TO THEIR RESPECTIVE ATTORNEYS OF 25 RECORD: 26 Defendant BALDWIN PARK UNIFIED SCHOOL DISTRICT (the “District”) hereby 27 moves the Court, in limine, for an Order to preclude Plaintiff, Plaintiffs counsel, and Plaintiffs 28 MUSICK, PEELER & GARRETT LLP 1168669.1 MOTION IN LIMINE NO. 3