On April 22, 2022 a
Motion,Ex Parte
was filed
involving a dispute between
Campos, Haydee Cruz,
and
American Honda Motor Co., Inc.,
Does 1-10,
for Breach of Contract/Warranty Unlimited
in the District Court of San Bernardino County.
Preview
KNIGHT LAW GROUP, LLP ELECTRONICALLY FILED
Roger Kimos (SBN 283 1 63) SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
r0gerk@knightlaw.com SAN BERNARDINO DISTRICT
Deepak Devabose (SBN 298890)
deepakd@knightlaw.com 10/19/2023 11:00 AM
10250 Constellation B1Vd., Suite 2500 By: Betty Davidson, DEPUTY
Los Angeles, CA 90067
\DOOQONUl-bUJNr—
Telephone: (310) 552-2250
Fax: (310) 552-7973
Attorneys for Plaintiff
HAYDEE CRUZ CAMPOS
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
HAYDEE CRUZ CAMPOS, Case No.2 CIVSB2208274
Plaintiff, Hon. Thomas Garza, Dep’t 827
VS.
PLAINTIFF’S MOTION IN LIMINE
NO. 3
AMERICAN HONDA MOTOR C0,, INC., a NOTICE OF MOTION AND
California Corporation, and DOES through
1 MOTION IN LIMINE TO PROHIBIT
10, inclusive, ARGUMENT OR TESTIMONY
THAT DEFENDANT CONFORMED
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Defendant.
THE VEHICLE WITHIN A
REASONABLE NUMBER OF
REPAIR ATTEMPTS BECAUSE
DEFENDANT REPAIRED A
OOQONUl-hUJNi—‘OKDOOQONUl-bUJNi—‘O
PARTICULAR COMPONENT
Trial: November 6, 2023
3 TO PROHIBIT TESTIMONY OR ARGUMENT THAT DEFENDANT CONFORMED
PLAINTIFF’S MIL NO.
THE VEHICLE WITHIN A REASONABLE NUMBER OF REPAIR ATTEMPTS BECAUSE DEFENDANT
REPAIRED A PARTICULAR COMPONENT
TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that Plaintiff HAYDEE CRUZ CAMPOS (“Plaintiff’) moves
the Court in limine for an order prohibiting Defendant AMERICAN HONDA MOTOR C0,, INC.
(“Defendant” or “HONDA) from offering testimony 0r argument Defendant conformed the vehicle
\DOOQONUl-bUJNr— t0 warranty within a reasonable number 0f repair attempts simply because it repaired a particular
component. This motion is based 0n Judicial Council 0f California Jury Instruction (“CACI”)
3201, 3202 and controlling case law.
Plaintiff further moves the Court to instruct all parties and their counsel, as well as require
counsel t0 advise all Witnesses 0f the following:
1. Not t0 attempt t0 convey to the jury, directly or indirectly, any of the facts
mentioned in this Motion Without first obtaining permission from the Court outside the presence
and hearing of the jury;
2. Not to make any reference to the fact that this Motion has been filed; and,
3. T0 warn and caution all Witnesses t0 strictly follow the same instructions.
This motion is based upon the supporting Memorandum 0f Points and Authorities, the
concurrently filed Declaration 0f Deepak Devabose, the papers and pleadings on file in this action,
NNNNNNNNNr—tr—tr—tr—tr—tr—tr—tr—tr—tr—t
and upon such further matters that may be presented at the hearing.
OOQONUl-hUJNi—‘OKDOOQONUl-bUJNi—‘O
Dated: October 19, 2023 KNIGHT LAW GROUP, LLP
PW DWaw
Deepgk Devabose, Esq.
Attorneys for Plaintiff
HAYDEE CRUZ CAMPOS
-1-
PLAINTIFFS’ MIL NO. 3 TO PROHIBIT TESTIMONY OR ARGUMENT THAT DEFENDANT CONFORMED
THE VEHICLE WITHIN A REASONABLE NUMBER OF REPAIR ATTEMPTS BECAUSE DEFENDANT
REPAIRED A PARTICULAR COMPONENT
Document Filed Date
October 19, 2023
Case Filing Date
April 22, 2022
Category
Breach of Contract/Warranty Unlimited
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KNIGHT LAW GROUP, LLP ELECTRONICALLY FILED Roger Kimos (SBN 283 1 63) SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO r0gerk@knightlaw.com SAN BERNARDINO DISTRICT Deepak Devabose (SBN 298890) deepakd@knightlaw.com 10/19/2023 11:00 AM 10250 Constellation B1Vd., Suite 2500 By: Betty Davidson, DEPUTY Los Angeles, CA 90067 \DOOQONUl-bUJNr— Telephone: (310) 552-2250 Fax: (310) 552-7973 Attorneys for Plaintiff HAYDEE CRUZ CAMPOS SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO HAYDEE CRUZ CAMPOS, Case No.2 CIVSB2208274 Plaintiff, Hon. Thomas Garza, Dep’t 827 VS. PLAINTIFF’S MOTION IN LIMINE NO. 3 AMERICAN HONDA MOTOR C0,, INC., a NOTICE OF MOTION AND California Corporation, and DOES through 1 MOTION IN LIMINE TO PROHIBIT 10, inclusive, ARGUMENT OR TESTIMONY THAT DEFENDANT CONFORMED NNNNNNNNNr—tr—tr—tr—tr—tr—tr—tr—tr—tr—t Defendant. THE VEHICLE WITHIN A REASONABLE NUMBER OF REPAIR ATTEMPTS BECAUSE DEFENDANT REPAIRED A OOQONUl-hUJNi—‘OKDOOQONUl-bUJNi—‘O PARTICULAR COMPONENT Trial: November 6, 2023 3 TO PROHIBIT TESTIMONY OR ARGUMENT THAT DEFENDANT CONFORMED PLAINTIFF’S MIL NO. THE VEHICLE WITHIN A REASONABLE NUMBER OF REPAIR ATTEMPTS BECAUSE DEFENDANT REPAIRED A PARTICULAR COMPONENT TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that Plaintiff HAYDEE CRUZ CAMPOS (“Plaintiff’) moves the Court in limine for an order prohibiting Defendant AMERICAN HONDA MOTOR C0,, INC. (“Defendant” or “HONDA) from offering testimony 0r argument Defendant conformed the vehicle \DOOQONUl-bUJNr— t0 warranty within a reasonable number 0f repair attempts simply because it repaired a particular component. This motion is based 0n Judicial Council 0f California Jury Instruction (“CACI”) 3201, 3202 and controlling case law. Plaintiff further moves the Court to instruct all parties and their counsel, as well as require counsel t0 advise all Witnesses 0f the following: 1. Not t0 attempt t0 convey to the jury, directly or indirectly, any of the facts mentioned in this Motion Without first obtaining permission from the Court outside the presence and hearing of the jury; 2. Not to make any reference to the fact that this Motion has been filed; and, 3. T0 warn and caution all Witnesses t0 strictly follow the same instructions. This motion is based upon the supporting Memorandum 0f Points and Authorities, the concurrently filed Declaration 0f Deepak Devabose, the papers and pleadings on file in this action, NNNNNNNNNr—tr—tr—tr—tr—tr—tr—tr—tr—tr—t and upon such further matters that may be presented at the hearing. OOQONUl-hUJNi—‘OKDOOQONUl-bUJNi—‘O Dated: October 19, 2023 KNIGHT LAW GROUP, LLP PW DWaw Deepgk Devabose, Esq. Attorneys for Plaintiff HAYDEE CRUZ CAMPOS -1- PLAINTIFFS’ MIL NO. 3 TO PROHIBIT TESTIMONY OR ARGUMENT THAT DEFENDANT CONFORMED THE VEHICLE WITHIN A REASONABLE NUMBER OF REPAIR ATTEMPTS BECAUSE DEFENDANT REPAIRED A PARTICULAR COMPONENT