On July 15, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Rowan, Sandra,
and
Does 1 Through 10, Inclusive,
General Motors Llc,
for Breach of Contract/Warranty Unlimited
in the District Court of San Bernardino County.
Preview
V OHBGEW V
F l L E
Supemorz COURT 0F cums.
—I
Tionna Dolin (SBN 29901 0) COUNTYQF SAN BERNARomo.sA
SAN BE“‘”-"RD‘N0 DISTRICT
e-mail: tdolinQDslpattomeycom
Debora Rabieian (SBN 315022) _
OCT 2 4 2023
e-mail: drabieian/d‘slpattomeyxom
STRATEGIC LEGAL PRACTICES
A PROFESSIONAL CORPORATION
1888 Century Park East. Floor 19
Los Angeles. CA 90067
Telephone: (3 0) 929-4900
l
BY w? J
79‘4“};
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A;
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OOOONO\UIAUJN
Facsimile: (310) 943-3838 de
Attorneys for Plaintiff,
0%?
SANDRA ROWAN
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
SANDRA ROWAN, CASE NO: CIVSBZI 19439
Plaintiff, Case Initiated: July I5, 2021
vs.
Hon. Michael A. Sachs
GENERAL MOTORS. LLC.; and DOES l Dept- 528-SBJC
through 10, inclusive,
PLAINTIFF’S MOTION IN LIMINE
Defendants. NO. 8 TO EXCLUDE EVIDENCE OR
ARGUMENT REGARDING
DEFENDANT’S §998 STATUTORY
OFFER TO COMPROMISE
[Filed Concurrently with Memorandum of
Points and Authorities; [Proposed] Order]
Complaint Filed: July 15. 2021
TRC: November 2, 2023
Trial: November 6, 2023
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that Plaintiff SANDRA ROWAN (“Plaintiff") hereby moves
this Court in limine for an Order providing the following:
1. Prohibiting Defendant GENERAL MOTORS LLC (“Defendant”) and
Defendant‘s experts. attorneys, and witnesses from introducing or attempting to introduce (either
Page I
PLAINTIFF’S MOTION IN LIMINE NO. 8 TO EXCLUDE EVIDENCE OR ARGUMENT REGARDING
DEFENDANT’S SECTION 998 STATUTORY OFFER TO COMPROMISE
directly or indirectly) any Settlement Offer to Compromise issued pursuant to Code of Civil
Procedure §998.
2. Prohibiting Defendant and its attorneys from introducing, or attempting to
introduce, any ofthe above evidence during the trial of the above-entitled action, unless and until
it is first determined to be admissible in evidence in a hearing held outside the presence and
\OMNQUI-PWNH
hearing of the jury;
3. Directing the attorneys for Defendant to instruct Defendant and its witnesses to
refrain from mentioning or referring to the above-described evidence in the presence or hearing
ofjurors or prospective jurors; and
4. Directing the attorneys for Defendant to immediately inform Defendant and its
witnesses of the terms and effect 0f the order in limine.
This Motion is based on the following Memorandum of Points & Authorities, the
Declaration of Tionna Dolin. the pleadings and records on file herein. and on oral and
documentary evidence as may be presented at the hearing on this motion.
Plaintiff‘s counsel advised opposing counsel 0f her intent to file this motion and initiated
NNNNNNNNNh—th—dv—I—‘u—tu—p—p—ap—y—a
a meet and confer effort in good faith with regards to the subject matter ofthis motion. As ofthe
time offiling this motion in limine, Defendant has not so stipulated. (Declaration ofTionna Dolin
OONONUIAWN’fiOOOONQUIAWN—‘o
Paragraph 2. Exhibit l).
Dated: October 23. 2023 STRATEGIC LEGAL PRACTICES, APC
L...—
By:
TION $
Attorney for
SANDRA ROWAN
Plaintiff.
Page 2
PLAINTIFF‘S MOTION 1N LIMINE NO. 8 TO EXCLUDE EVIDENCE OR ARGUMENT REGARDING
DEFENDANT‘S SECTION 998 STATUTORY OFFER TO COMPROMISE
Document Filed Date
October 24, 2023
Case Filing Date
July 15, 2021
Category
Breach of Contract/Warranty Unlimited
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V OHBGEW V F l L E Supemorz COURT 0F cums. —I Tionna Dolin (SBN 29901 0) COUNTYQF SAN BERNARomo.sA SAN BE“‘”-"RD‘N0 DISTRICT e-mail: tdolinQDslpattomeycom Debora Rabieian (SBN 315022) _ OCT 2 4 2023 e-mail: drabieian/d‘slpattomeyxom STRATEGIC LEGAL PRACTICES A PROFESSIONAL CORPORATION 1888 Century Park East. Floor 19 Los Angeles. CA 90067 Telephone: (3 0) 929-4900 l BY w? J 79‘4“}; ' E' A; " OOOONO\UIAUJN Facsimile: (310) 943-3838 de Attorneys for Plaintiff, 0%? SANDRA ROWAN SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO SANDRA ROWAN, CASE NO: CIVSBZI 19439 Plaintiff, Case Initiated: July I5, 2021 vs. Hon. Michael A. Sachs GENERAL MOTORS. LLC.; and DOES l Dept- 528-SBJC through 10, inclusive, PLAINTIFF’S MOTION IN LIMINE Defendants. NO. 8 TO EXCLUDE EVIDENCE OR ARGUMENT REGARDING DEFENDANT’S §998 STATUTORY OFFER TO COMPROMISE [Filed Concurrently with Memorandum of Points and Authorities; [Proposed] Order] Complaint Filed: July 15. 2021 TRC: November 2, 2023 Trial: November 6, 2023 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that Plaintiff SANDRA ROWAN (“Plaintiff") hereby moves this Court in limine for an Order providing the following: 1. Prohibiting Defendant GENERAL MOTORS LLC (“Defendant”) and Defendant‘s experts. attorneys, and witnesses from introducing or attempting to introduce (either Page I PLAINTIFF’S MOTION IN LIMINE NO. 8 TO EXCLUDE EVIDENCE OR ARGUMENT REGARDING DEFENDANT’S SECTION 998 STATUTORY OFFER TO COMPROMISE directly or indirectly) any Settlement Offer to Compromise issued pursuant to Code of Civil Procedure §998. 2. Prohibiting Defendant and its attorneys from introducing, or attempting to introduce, any ofthe above evidence during the trial of the above-entitled action, unless and until it is first determined to be admissible in evidence in a hearing held outside the presence and \OMNQUI-PWNH hearing of the jury; 3. Directing the attorneys for Defendant to instruct Defendant and its witnesses to refrain from mentioning or referring to the above-described evidence in the presence or hearing ofjurors or prospective jurors; and 4. Directing the attorneys for Defendant to immediately inform Defendant and its witnesses of the terms and effect 0f the order in limine. This Motion is based on the following Memorandum of Points & Authorities, the Declaration of Tionna Dolin. the pleadings and records on file herein. and on oral and documentary evidence as may be presented at the hearing on this motion. Plaintiff‘s counsel advised opposing counsel 0f her intent to file this motion and initiated NNNNNNNNNh—th—dv—I—‘u—tu—p—p—ap—y—a a meet and confer effort in good faith with regards to the subject matter ofthis motion. As ofthe time offiling this motion in limine, Defendant has not so stipulated. (Declaration ofTionna Dolin OONONUIAWN’fiOOOONQUIAWN—‘o Paragraph 2. Exhibit l). Dated: October 23. 2023 STRATEGIC LEGAL PRACTICES, APC L...— By: TION $ Attorney for SANDRA ROWAN Plaintiff. Page 2 PLAINTIFF‘S MOTION 1N LIMINE NO. 8 TO EXCLUDE EVIDENCE OR ARGUMENT REGARDING DEFENDANT‘S SECTION 998 STATUTORY OFFER TO COMPROMISE