On March 21, 2019 a
Party Discovery
was filed
involving a dispute between
Mahaffey, Ashley,
Mahaffey, Brian,
and
Colorama Wholesale Nursery,
Medina, Jose,
Wilson, Richard,
for Personal Injury Motor Vehicle Unlimited
in the District Court of San Bernardino County.
Preview
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Kimberly S. Oberrecht [C.S.B. No. 190794] sureriotedutir &. earn 1A
COUNTY OF SAN BERNARDINO:
Cherie A. Enge [C.S.B. No. 134998] SAN BERNARSING SISTPICT
Cheyenne J. Page [C.S.B. No. 323354]
HORTON, OBERRECHT & KIRKPATRICK MAK 25 2023
101 W. Broadway, Suite 600
San Diego, California 92101
(619) 232-1183 * (619) 696-5719 [facsimile] w
GREG TABIHAMT, DEPLITY
Attorneys for Defendants RICHARD WILSON; JOSE MEDINA; and COLORAMA
WHOLESALE NURSERY dba COLORAMA
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN BERNARDINO
CENTRAL JUDICIAL DISTRICT
10
BRIAN MAHAFFEY & ASHLEY MAHAFFEY, ) CASE NO. CIVDS1908657
11
Plaintiff, MOTION IN LIMINE FOR AN
12 ORDER EXCLUDING EXPERT
vs. OPINION NOT DISCLOSED
13 DURING DEPOSITION [2 OF 12]
RICHARD WILSON; JOSE MEDINA,
14 COLORAMA WHOLESALE NURSERY dba Action Filed: March 21, 2019
COLORAMA, and DOES | through 100, Trial Date: April 10, 2022
15 Inclusive, Dept. S15
16 Defendants.
17
18 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD HEREIN:
19 Defendants RICHARD WILSON; JOSE MEDINA; and COLORAMA WHOLESALE
20 NURSERY dba COLORAMA (“Defendants”) move this Court for any order precluding any expert
21 opinion that was not disclosed during their deposition.
22 I
23 INTRODUCTION
24 The Court should preclude Plaintiffs BRIAN MAHAFFEY and ASHLEY MAHAFFEY
25 (“Plaintiffs”) from introducing evidence of any expert opinion that was not disclosed during
26 deposition. Plaintiffs have designated five retained experts, 17 non-retained experts, and one “party
27 expert” in this matter. Defendants have diligently taken each retained expert’s deposition as well
28 as many non-retained experts’ depositions. Some experts have been deposed multiple times due to
MOTION IN LIMINE FOR AN ORDER EXCLUDING EXPERT OPINION NOT DISCLOSED DURING
DEPOSITION [2 OF 12]
GACLIENTS\5845\TRIAL\Defs MILs\MIL No. 2 Limit Experts. wpd 1
SUPER! HOR
REC, EIVED
COUNTY oF SAN SE CALIFORNIA
MAR 28 2923
Gloria Marin
Document Filed Date
March 28, 2023
Case Filing Date
March 21, 2019
Category
Personal Injury Motor Vehicle Unlimited
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~~ Kimberly S. Oberrecht [C.S.B. No. 190794] sureriotedutir &. earn 1A COUNTY OF SAN BERNARDINO: Cherie A. Enge [C.S.B. No. 134998] SAN BERNARSING SISTPICT Cheyenne J. Page [C.S.B. No. 323354] HORTON, OBERRECHT & KIRKPATRICK MAK 25 2023 101 W. Broadway, Suite 600 San Diego, California 92101 (619) 232-1183 * (619) 696-5719 [facsimile] w GREG TABIHAMT, DEPLITY Attorneys for Defendants RICHARD WILSON; JOSE MEDINA; and COLORAMA WHOLESALE NURSERY dba COLORAMA SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN BERNARDINO CENTRAL JUDICIAL DISTRICT 10 BRIAN MAHAFFEY & ASHLEY MAHAFFEY, ) CASE NO. CIVDS1908657 11 Plaintiff, MOTION IN LIMINE FOR AN 12 ORDER EXCLUDING EXPERT vs. OPINION NOT DISCLOSED 13 DURING DEPOSITION [2 OF 12] RICHARD WILSON; JOSE MEDINA, 14 COLORAMA WHOLESALE NURSERY dba Action Filed: March 21, 2019 COLORAMA, and DOES | through 100, Trial Date: April 10, 2022 15 Inclusive, Dept. S15 16 Defendants. 17 18 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD HEREIN: 19 Defendants RICHARD WILSON; JOSE MEDINA; and COLORAMA WHOLESALE 20 NURSERY dba COLORAMA (“Defendants”) move this Court for any order precluding any expert 21 opinion that was not disclosed during their deposition. 22 I 23 INTRODUCTION 24 The Court should preclude Plaintiffs BRIAN MAHAFFEY and ASHLEY MAHAFFEY 25 (“Plaintiffs”) from introducing evidence of any expert opinion that was not disclosed during 26 deposition. Plaintiffs have designated five retained experts, 17 non-retained experts, and one “party 27 expert” in this matter. Defendants have diligently taken each retained expert’s deposition as well 28 as many non-retained experts’ depositions. Some experts have been deposed multiple times due to MOTION IN LIMINE FOR AN ORDER EXCLUDING EXPERT OPINION NOT DISCLOSED DURING DEPOSITION [2 OF 12] GACLIENTS\5845\TRIAL\Defs MILs\MIL No. 2 Limit Experts. wpd 1 SUPER! HOR REC, EIVED COUNTY oF SAN SE CALIFORNIA MAR 28 2923 Gloria Marin