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  • HENRY-V-SUNRISE FORD, INC. ET AL Print Business Tort/Unfair Business Practice Unlimited  document preview
  • HENRY-V-SUNRISE FORD, INC. ET AL Print Business Tort/Unfair Business Practice Unlimited  document preview
  • HENRY-V-SUNRISE FORD, INC. ET AL Print Business Tort/Unfair Business Practice Unlimited  document preview
  • HENRY-V-SUNRISE FORD, INC. ET AL Print Business Tort/Unfair Business Practice Unlimited  document preview
						
                                

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FILED SUPERIOR COURT COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT oxrofi 1CAp AUG 19 2020 oe n m The Superior Court 03 OF T HE BY l y q r FS a o DEPUI i 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