On January 08, 2013 a
Motion,Ex Parte
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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@ ORIGINAL @
BOWMAN AND BROOKE LLP
Anthony S. Thomas (SBN 149284 FILED
Ss us! Court of Cai ia
Thomas M. Klein (Admitted Pro Hac Vice’ Gounty of Los Ang
Anthony J. Parascandola (SBN 140217)
970 West 190th Street, Suite 700
Torrance, CA 90: Wat 23 2017
Tel: 310) 768-3068
Sh ert Carte: Exeguie OflicariCierk
Fax: 310, 719-1019 _ Dewey
By. Raul Sanchez
Attorneys for Defendants, GENERAL MOTORS LLC,
RALLY AUTO, and CHEVROLET OF MONTEBELLO
SUPERIOR COURT OF CALIFORNIA
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
413 Plaintiff,
[DEFENDANTS' MOTION IN LIMINE
14 vs. NO. 3 OF 11]
15 GENERAL MOTORS COMPANY; REPLY IN SUPPORT OF GENERAL
ARSEV, INC.; CHEVROLET OF MOTORS LLC, RALLY AUTO, and
16 MONTEBELLO; RALLY AUTO GROUP, CHEVROLET OF MONTEBELLO'S
, MOTION IN LIMINE NO. 3 TO
17 PRECLUDE THE USE OF THE
Defendants. CONSUMER EXPECTATIONS TEST
18 AND FOR AN ORDER THAT THE
PROPER INSTRUCTION FOR DESIGN
19 DEFECT IS THE RISK-BENEFIT TEST;
DECLARATION OF ANTHONY J.
20 PARASCANDOLA
21 Action Filed: May 12, 2015
Trial Date: June 6, 2017
22
23 TO ALL PARTIES HEREIN AND THEIR COUNSEL OF RECORD:
24 Defendants, GENERAL MOTORS LLC, RALLY AUTO, and CHEVROLET OF
mp
wn 25 MONTEBELLO'S (hereinafter collectively referred to as "the GM Defendants") submit
te
26 the following Reply Brief in support of their Motion in Limine No. 3 to Preclude the Use
bed of the Consumer Expectations Test and for an Order that the Proper Instruction for
™Deo 27
vl 28 Design Defect Is the Risk-Benefit Test.
18016726v4 1
REPLY IN SUPPORT OF GENERAL MOTORS LLC, RALLY AUTO, and CHEVROLET OF MONTEBELLO'S
MOTION IN LIMINE NO. 3 TO PRECLUDE THE USE OF THE CONSUMER EXPECTATIONS TEST AND FOR AN
ORDER THAT THE PROPER INSTRUCTION FOR DESIGN DEFECT IS THE RISK-BENEFIT TEST
Document Filed Date
May 23, 2017
Case Filing Date
January 08, 2013
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@ ORIGINAL @ BOWMAN AND BROOKE LLP Anthony S. Thomas (SBN 149284 FILED Ss us! Court of Cai ia Thomas M. Klein (Admitted Pro Hac Vice’ Gounty of Los Ang Anthony J. Parascandola (SBN 140217) 970 West 190th Street, Suite 700 Torrance, CA 90: Wat 23 2017 Tel: 310) 768-3068 Sh ert Carte: Exeguie OflicariCierk Fax: 310, 719-1019 _ Dewey By. Raul Sanchez Attorneys for Defendants, GENERAL MOTORS LLC, RALLY AUTO, and CHEVROLET OF MONTEBELLO SUPERIOR COURT OF CALIFORNIA 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: 93 413 Plaintiff, [DEFENDANTS' MOTION IN LIMINE 14 vs. NO. 3 OF 11] 15 GENERAL MOTORS COMPANY; REPLY IN SUPPORT OF GENERAL ARSEV, INC.; CHEVROLET OF MOTORS LLC, RALLY AUTO, and 16 MONTEBELLO; RALLY AUTO GROUP, CHEVROLET OF MONTEBELLO'S , MOTION IN LIMINE NO. 3 TO 17 PRECLUDE THE USE OF THE Defendants. CONSUMER EXPECTATIONS TEST 18 AND FOR AN ORDER THAT THE PROPER INSTRUCTION FOR DESIGN 19 DEFECT IS THE RISK-BENEFIT TEST; DECLARATION OF ANTHONY J. 20 PARASCANDOLA 21 Action Filed: May 12, 2015 Trial Date: June 6, 2017 22 23 TO ALL PARTIES HEREIN AND THEIR COUNSEL OF RECORD: 24 Defendants, GENERAL MOTORS LLC, RALLY AUTO, and CHEVROLET OF mp wn 25 MONTEBELLO'S (hereinafter collectively referred to as "the GM Defendants") submit te 26 the following Reply Brief in support of their Motion in Limine No. 3 to Preclude the Use bed of the Consumer Expectations Test and for an Order that the Proper Instruction for ™Deo 27 vl 28 Design Defect Is the Risk-Benefit Test. 18016726v4 1 REPLY IN SUPPORT OF GENERAL MOTORS LLC, RALLY AUTO, and CHEVROLET OF MONTEBELLO'S MOTION IN LIMINE NO. 3 TO PRECLUDE THE USE OF THE CONSUMER EXPECTATIONS TEST AND FOR AN ORDER THAT THE PROPER INSTRUCTION FOR DESIGN DEFECT IS THE RISK-BENEFIT TEST