On August 23, 2018 a
Order
was filed
involving a dispute between
Henry, Billy C,
Sunrise Ford Inc A California Corporation,
and
Bruncati, Daniel,
Bruncati, James,
Bruncati, Robert,
Does 2 Through 50,
Ford Motor Company,
Ford Motor Credit Company,
Sunrise Ford, Inc.,
for Business Tort
in the District Court of San Bernardino County.
Preview
FILED
SUPERIOR COURT
COUNTY OF SAN BERNARDINO
SAN BERNARDINO DISTRICT
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1CAp AUG 19 2020
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The Superior Court
03
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FS a
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MAILIN DDRESS
State of California SAN BERNARDINO COUNTY SUPERIOR COURT
CHAMBERS OF SAN BERNARDINO JUSTICE CENTER
EuA V PIROZZI SAN BERNARDINO 247 W THIRD STREET
JUDGE OF THE SUPERIOR COURT SAN BERNARDINO CALIFORNIA 92392
San Bernardino County Superior Court
Department 525 San Bernardino District
Final Status Conference Order
Judge Elia V Pirozzi
CASE NAME HENRY V SUNRISE FORD INC ET AL
CIVDS1822222
CASE NO
Final Status Conference Trial Management Conference FSC and Trial dates having been set
in this case the COURT ORDERS AS FOLLOWS
1
Appearances by Counsel at FSC The lawyer designated to try the case must be present
at the FSC
2 Meet and Confer Counsel are ordered to meet and confer at least ten 10 days before
the FSC to exchange discuss and prepare for submission to the Court the jury
instructions a Statement of the Case exhibits exhibit lists and witness lists
3 Motions in Limine No later than thirty 30 calendar days before the FSC any party
wishing to file a motion in limine must meet and confer with the other parties to see if
they can reach agreement without the necessity of a motion If the meet and confer does
not resolve the matter then any party wishing to file any motions in limine is to file and
serve those motions in limine no later than ten 10 calendar days before the FSC If more
than two motions in limine are filed by a party a binder containing the motions
separated by tabs and an index of the motions shall be provided Other parties are to
review those motions and joinder in the motions will be unnecessary any party may at
its later oral request be deemed for the record to have joined in any motion Opposition
to any motions shall be filed and served five 5 court days before the FSC Both the
motions and oppositions should consist only of a brief synopsis of the parties positions
Opposed motions shall if requested at the FSC be set by the Court for separate hearing
with a schedule for full briefing established Attached hereto as Exhibit A is a list of
sua sponte rulings by the Court for which it is not necessary to file a motion in limine
counsel are requested not to file duplicate motions but may file opposition to the sua
sponte rulings Counsel are expected to be familiar with Kelly v New West Federal
Savings 2d Dist 1996 49 CaLApp 4th 659 and Amtower v Photon Dynamics Inc 6th
Dist 2008 158 Ca1 App 4th 1582 Motions in limine shall be prepared in accordance with
Local Rule of Court 415
Hon E Pirozzi updated 7 19 20 1
a
General Drafting Guidelines Each motion in limine should be filed as a separate
motion with its own points and authorities and supporting declarations and other
evidence Please do not staple or bundle the motions in limine together with other
motions in limine or as part of an omnibus motion in limine setting forth a
series of motions in a single pleading The caption in each motion in limine
should clearly and concisely identify the subject matter of the motion
b Complex Motions in Limine Complex motions in limine shall be filed and served
no later than fifteen 15 court days prior to the FSC It is up to counsel to
determine whether a motion in limine qualifies as complex but factors to
consider in making this assessment are whether 1 the motion is lengthy or 2 the
motion requires independent research by the court Oppositions to complex
motions in limine shall be filed and served no later than five 5 court days prior
to the FSC Cases designated as complex are governed pursuant to Local Rule of
Court 412
4 Docurnent Filing Requirements The following documents shall be filed directly in
Department S25 by 10 00 a m at least three 3 court days prior to the FSC
a
Jury Instructions Jury instructions shall be filed in accordance with the
following procedure
1 A packet of all requested jury instructions to which there is no objection
by any party
2 A separate packet of all requested instructions to which there are
objections As to each such instruction the objecting party must
separately submit in writing a brief statement of the grounds for the
objection Any objection not stated consistent with this process shall be
deemed waived except on a showing of good cause
3 Plaintiff must submit complete CACI 200 Burden of Proof Obligation to
Prove instructions for each cause of action and defendant for each
affirmative defense on which such party intends to prove Proposed
special instructions should be on a separate sheet per instruction At the
FSC the Court will provide dates for the exchange of objections to such
instructions as well as for proposed additional instructions from other
parfies and will set a deadline for the parties to meet and confer regarding
differences on the subject
Each instruction must indicate the party or parties requesting the
instruction All blank areas on CACI instructions must be completed and
any irrelevant portions deleted
b Statement of the Case A short non argumentative written statement of the case
to be read to the jury for every trial shall be jointly filed in the form provided in
the Trial Guidelines or in another forinat acceptable to the Court
Hon E Pirozzi updated 7 19 20 2
Document Filed Date
August 19, 2020
Case Filing Date
August 23, 2018
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