On January 08, 2013 a
Trial Materials
was filed
involving a dispute between
Campbell Kimberly,
Kimberly Campbell By And Through Her,
and
Arsev Inc.,
Arsev Inc. Dismissed 5-24-17,
Chevrolet Of Montebello,
General Motors Company,
Rally Auto Group Inc.,
for civil
in the District Court of Los Angeles County.
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@
BOWMAN AND BROOKE LLP
Anthony S. Thomas (SBN 149284)
Thomas M. Klein (Admitted Pro Hac Vice)
Anthony J. Parascandola (SBN 140217) FILED
970 West 190th Street, Suite 700 Superior Court of California
Torrance, CA 90502 County of Los Angeles
Tel: (310) 768-3068
Fax: (310) 719-1019 OCT 04 2017
Sherri R. Carter, Exec Officer/Clerk
"iL Moses Ade
Attorneys for Defendants, GENERAL MOTORS LLC,
RALLY AUTO, and CHEVROLET OF MONTEBELLO By. » Deputy
Soto
SUPERIOR COURT OF CALIFORNIA
9 COUNTY OF LOS ANGELES
10
11 KIMBERLY CAMPBELL, by and through CASE NO. BC581592
her Guardian Ad Litem, ALEXANDER
12 CAMPBELL, Assigned: Hon. Robert B. Broadbelt
Department: 93
13 Plaintiff,
OMNIBUS REPLY BRIEF IN SUPPORT
14 vs. OF THE GM DEFENDANTS’ MOTION
TO INSPECT STEERING GEAR AND
15 GENERAL MOTORS COMPANY; AUGMENT WITNESS LIST
ARSEV, INC.; CHEVROLET OF.
16 MONTEBELLO; RALLY AUTO GROUP, Date: October 13, 2017 and
INC., October 16, 2017
17
Defendants. Time: 1:30 p.m.
"93"
18 Dept.:
19 Action Filed: May 12, 2015
Trial Date: November 14, 2017
20
21 ' INTRODUCTION
22 The instant motion is not about discovery cutoffs or delaying the trial. To the
23 contrary, it is about both sides being fully prepared to address the legal issues
24 presented in this lawsuit--without wasting the jury’s time with rank speculation and
25 conjecture. See Sargon v Univ. of Southern Cal. (2012) 55 Cal.4"" 747 (addressing trial
26 court's duty to act as a gatekeeper to exclude speculative expert testimony).
27 th Simply put, this case is about either an alleged steering defect in a 2013
28 4 Chevrolet Cruze or a plaintiff who fell asleep at the wheel and drove into oncoming
ne 18599768v1 4
pe OMNIBUS REPLY IN SUPPORT OF GM DEFENDANTS’ MOTION TO INSPECT THE STEERING GEAR AND
eg AUGMENT EXPERT WITNESS LIST; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF
ANTHONY S. THOMAS
Document Filed Date
October 04, 2017
Case Filing Date
January 08, 2013
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@ BOWMAN AND BROOKE LLP Anthony S. Thomas (SBN 149284) Thomas M. Klein (Admitted Pro Hac Vice) Anthony J. Parascandola (SBN 140217) FILED 970 West 190th Street, Suite 700 Superior Court of California Torrance, CA 90502 County of Los Angeles Tel: (310) 768-3068 Fax: (310) 719-1019 OCT 04 2017 Sherri R. Carter, Exec Officer/Clerk "iL Moses Ade Attorneys for Defendants, GENERAL MOTORS LLC, RALLY AUTO, and CHEVROLET OF MONTEBELLO By. » Deputy Soto SUPERIOR COURT OF CALIFORNIA 9 COUNTY OF LOS ANGELES 10 11 KIMBERLY CAMPBELL, by and through CASE NO. BC581592 her Guardian Ad Litem, ALEXANDER 12 CAMPBELL, Assigned: Hon. Robert B. Broadbelt Department: 93 13 Plaintiff, OMNIBUS REPLY BRIEF IN SUPPORT 14 vs. OF THE GM DEFENDANTS’ MOTION TO INSPECT STEERING GEAR AND 15 GENERAL MOTORS COMPANY; AUGMENT WITNESS LIST ARSEV, INC.; CHEVROLET OF. 16 MONTEBELLO; RALLY AUTO GROUP, Date: October 13, 2017 and INC., October 16, 2017 17 Defendants. Time: 1:30 p.m. "93" 18 Dept.: 19 Action Filed: May 12, 2015 Trial Date: November 14, 2017 20 21 ' INTRODUCTION 22 The instant motion is not about discovery cutoffs or delaying the trial. To the 23 contrary, it is about both sides being fully prepared to address the legal issues 24 presented in this lawsuit--without wasting the jury’s time with rank speculation and 25 conjecture. See Sargon v Univ. of Southern Cal. (2012) 55 Cal.4"" 747 (addressing trial 26 court's duty to act as a gatekeeper to exclude speculative expert testimony). 27 th Simply put, this case is about either an alleged steering defect in a 2013 28 4 Chevrolet Cruze or a plaintiff who fell asleep at the wheel and drove into oncoming ne 18599768v1 4 pe OMNIBUS REPLY IN SUPPORT OF GM DEFENDANTS’ MOTION TO INSPECT THE STEERING GEAR AND eg AUGMENT EXPERT WITNESS LIST; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF ANTHONY S. THOMAS