On December 14, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
Reyes, Veronica,
and
Does 1 Through 100, Inclusive,
Does 2 Through 100, Inclusive,
Knolls West Convalescent Hospital,
Knolls West Post Acute Llc,
Knolls West Post Acute, Llc,
Rios, Leila,
Victor Valley Medical Center,
for Medical Malpractice Unlimited
in the District Court of San Bernardino County.
Preview
ELECTRONICALLY FILED
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
SAN BERNARDINO DISTRICT
Alexander F. Giovanniello (CSB # 125562) .
10/19/2023 2'18 PM
Martin R. Boags (CSB # 178704)
GIOVANNIELLO LAW GROUP By: Gloria Ponillo, DEPUTY
One Pomte Drlve, Sulte 300
Brea, California 92821
Ph: (714) 364-4000
Fax: (714) 364-4001
service@giolawgroup.com
\DOONQUI-bUJNH
Attorneys for Defendants:
KNOLLS WEST POST ACUTE, LLC
and LEILA RIOS
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
VERONICA REYES, an individual; Case No.2 CIVSB2028 140
VERONICA REYES, successor-in-interest
0f decedent ALICE REYES, NOTICE OF MOTION AND MOTION IN
LIMINE TO PRECLUDE ALL EXPERTS
Plaintiff, vvvvvvvv
AND EXPERT OPINIONS NOT PROPERLY
DISCLOSED PURSUANT TO CODE OF
VS. CIVIL PROCEDURE §2034.010, ET. SEQ.
BY DEFENDANTS KNOLLS WEST POST
KNOLLS WEST CONVALESCENT ) ACUTE, LLC AND LEILA RIOS
HOSPITAL, unknown entity; KNOLLS )
WEST POST ACUTE LLC, a California )
NNNNNNNNNr—tr—tr—tr—tr—tr—tr—tr—tr—tr—t
corporation; LEILA RIOS, an individual; ) [Motion in Limine No. 15 of 19]
and DOES 1 through 100 inclusive, )
)
Defendants. ) TRIAL: November 6, 2023
) TIME: 10:00 a.m.
) DEPT: $28
OOQQUI-PUJNHOKDOOQQUI-bUJNHO
3
) JUDGE: Hon. Michael A. Sachs
)
) Complaint filed December 2 1 2020 ,
)
) Trial scheduled November 6, 2023
)
TO THE COURT, ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that Defendants KNOLLS WEST POST ACUTE, LLC and
LEILA RIOS (hereinafter referred to as “Defendants”) hereby move this Court, located at 247
West Third Street, San Bernardino, CA 92415, for an order, in limine, t0 preclude all experts and
expert opinions not properly disclosed pursuant to Code of Civil Procedure §2034.010, et. seq.,
i
NOTICE OF MOTION AND MOTION IN LIMINE TO PRECLUDE ALL EXPERTS AND EXPERT OPINIONS
NOT PROPERLY DISCLOSED PURSUANT TO CODE OF CIVIL PROCEDURE §2034.010, ET. SEQ. BY
DEFENDANTS KNOLLS WEST POST ACUTE, LLC AND LEILA RIOS
[Motion in Limine No. 15 of 19]
as well as any reference t0 the filing or granting of this motion in limine.
This motion is based on the grounds that Code 0f Civil Procedure §2034.260 describes
the procedure by Which plaintiffs are t0 designate their experts. Code 0f Civil Procedure
§2034.280 describes the procedure by Which plaintiffs are required to provide a supplemental
designation. Finally, Code 0f Civil Procedure §2034.300 requires this Court t0 exclude from
\OOOQONUIAUJNH
evidence any expert opinion 0f any witness Plaintiff failed to disclose pursuant t0 Code 0f Civil
Procedure §2034.260. This motion is based 0n the attached Memorandum of Points and
Authorities, upon the pleadings herein, and upon such evidence, oral and documentary, that may
be presented at the hearing.
Dated: October 19, 2023
WWW GIOVANNIELLO LAW GROUP
Alexatfder F. Giovanniello
Martin R. Boags
Attorneys for Defendants:
KNOLLS WEST POST ACUTE, LLC
and LEILA RIOS
NNNNNNNNNr—tr—tr—tr—tr—tr—tr—tr—tr—tr—t
OOQONUIAUJNHOKOOOQQUIAUJNHO
ii
NOTICE OF MOTION AND MOTION IN LIMINE TO PRECLUDE ALL EXPERTS AND EXPERT OPINIONS
NOT PROPERLY DISCLOSED PURSUANT TO CODE OF CIVIL PROCEDURE §2034.010, ET. SEQ. BY
DEFENDANTS KNOLLS WEST POST ACUTE, LLC AND LEILA RIOS
[Motion in Limine No. 15 0f 19]
Document Filed Date
October 19, 2023
Case Filing Date
December 14, 2020
Category
Medical Malpractice Unlimited
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ELECTRONICALLY FILED SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT Alexander F. Giovanniello (CSB # 125562) . 10/19/2023 2'18 PM Martin R. Boags (CSB # 178704) GIOVANNIELLO LAW GROUP By: Gloria Ponillo, DEPUTY One Pomte Drlve, Sulte 300 Brea, California 92821 Ph: (714) 364-4000 Fax: (714) 364-4001 service@giolawgroup.com \DOONQUI-bUJNH Attorneys for Defendants: KNOLLS WEST POST ACUTE, LLC and LEILA RIOS SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO VERONICA REYES, an individual; Case No.2 CIVSB2028 140 VERONICA REYES, successor-in-interest 0f decedent ALICE REYES, NOTICE OF MOTION AND MOTION IN LIMINE TO PRECLUDE ALL EXPERTS Plaintiff, vvvvvvvv AND EXPERT OPINIONS NOT PROPERLY DISCLOSED PURSUANT TO CODE OF VS. CIVIL PROCEDURE §2034.010, ET. SEQ. BY DEFENDANTS KNOLLS WEST POST KNOLLS WEST CONVALESCENT ) ACUTE, LLC AND LEILA RIOS HOSPITAL, unknown entity; KNOLLS ) WEST POST ACUTE LLC, a California ) NNNNNNNNNr—tr—tr—tr—tr—tr—tr—tr—tr—tr—t corporation; LEILA RIOS, an individual; ) [Motion in Limine No. 15 of 19] and DOES 1 through 100 inclusive, ) ) Defendants. ) TRIAL: November 6, 2023 ) TIME: 10:00 a.m. ) DEPT: $28 OOQQUI-PUJNHOKDOOQQUI-bUJNHO 3 ) JUDGE: Hon. Michael A. Sachs ) ) Complaint filed December 2 1 2020 , ) ) Trial scheduled November 6, 2023 ) TO THE COURT, ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that Defendants KNOLLS WEST POST ACUTE, LLC and LEILA RIOS (hereinafter referred to as “Defendants”) hereby move this Court, located at 247 West Third Street, San Bernardino, CA 92415, for an order, in limine, t0 preclude all experts and expert opinions not properly disclosed pursuant to Code of Civil Procedure §2034.010, et. seq., i NOTICE OF MOTION AND MOTION IN LIMINE TO PRECLUDE ALL EXPERTS AND EXPERT OPINIONS NOT PROPERLY DISCLOSED PURSUANT TO CODE OF CIVIL PROCEDURE §2034.010, ET. SEQ. BY DEFENDANTS KNOLLS WEST POST ACUTE, LLC AND LEILA RIOS [Motion in Limine No. 15 of 19] as well as any reference t0 the filing or granting of this motion in limine. This motion is based on the grounds that Code 0f Civil Procedure §2034.260 describes the procedure by Which plaintiffs are t0 designate their experts. Code 0f Civil Procedure §2034.280 describes the procedure by Which plaintiffs are required to provide a supplemental designation. Finally, Code 0f Civil Procedure §2034.300 requires this Court t0 exclude from \OOOQONUIAUJNH evidence any expert opinion 0f any witness Plaintiff failed to disclose pursuant t0 Code 0f Civil Procedure §2034.260. This motion is based 0n the attached Memorandum of Points and Authorities, upon the pleadings herein, and upon such evidence, oral and documentary, that may be presented at the hearing. Dated: October 19, 2023 WWW GIOVANNIELLO LAW GROUP Alexatfder F. Giovanniello Martin R. Boags Attorneys for Defendants: KNOLLS WEST POST ACUTE, LLC and LEILA RIOS NNNNNNNNNr—tr—tr—tr—tr—tr—tr—tr—tr—tr—t OOQONUIAUJNHOKOOOQQUIAUJNHO ii NOTICE OF MOTION AND MOTION IN LIMINE TO PRECLUDE ALL EXPERTS AND EXPERT OPINIONS NOT PROPERLY DISCLOSED PURSUANT TO CODE OF CIVIL PROCEDURE §2034.010, ET. SEQ. BY DEFENDANTS KNOLLS WEST POST ACUTE, LLC AND LEILA RIOS [Motion in Limine No. 15 0f 19]