On December 16, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Whipple, Jason,
and
Does 1 To 10,
General Motors Llc,
for Breach of Contract/Warranty Unlimited
in the District Court of San Bernardino County.
Preview
WEST POINT LEGAL ELECTRONICALLY FILED
SUPERIOR COURT OF CALIFORNIA
Bryan Altman (SBN 122976) COUNTY 0F SAN BERNARDINO
Andrew Jung (SBN 336002) SAN BERNARDINO DISTRICT
10990 Wllshlre B1Vd., Sulte 220
1005/2023 3:41 PM
Los Angeles, CA 90024
Telephone; (310) 277- 8481 By: Gloria Portillo, DEPUTY
Fax: (3 10) 277-8483
QUILL & ARROW, LLP
Kevin Y. Jacobson, Esq. (SBN 320532)
10900 Wilshire Blvd., Suite 300
Los Angeles, CA 90024
Telephone: (3 10) 933-4271
Facsimile: (3 10) 889-0645
Attorneys for Plaintiff,
W
10 JASON WHIPPLE
SUPERIOR COURT OF CALIFORNIA
11
COUNTY OF SAN BERNARDINO
12
JASON WHIPPLE, an individual, Case No.:
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Plamtlff’
°
Assigned t0 the Hon. Khymberli S. Apaloo
14 in Department S25-SBJC
VS'
15 PLAINTIFF’S MOTION IN LIMINE
NO. 4
16
S&TEfifififiSTgfipiic’Sfiifi‘éfi NOTICE 0F MOTION AND
17
thmu g h 10
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inclfisive
MOTION INLIMINE T0 PROHIBIT
’ ’
DEFENDANT FROM ASSERTING
18 DEFENSES OR OFFERING
TESTIMONY NOT GIVEN AT
19 Defendants. DEPOSITION
20 Date Filed: February 16, 2021
Trial Date: November 6, 2023
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PLAINTIFF’S MOTION INLIMINE NO. 4
TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that Plaintiff JASON WHIPPLE (“Plaintiff”) moves the Court
in limine for an order prohibiting Defendant from asserting defenses not given at deposition.
Plaintiff further moves the Court to instruct all parties and their counsel, as well as require
counsel to advise all Witnesses of the following:
1. Not t0 attempt t0 convey t0 the jury, directly 0r indirectly, any ofthe facts mentioned
in this Motion without first obtaining permission from the Court outside the presence and hearing
of the jury;
2. Not t0 make any reference t0 the fact that this Motion has been filed; and,
10 3. T0 warn and caution all witnesses to strictly follow the same instructions.
11 This motion is based upon the supporting Memorandum of Points and Authorities, the
12 Declaration 0f Andrew Jung, Esq. attached hereto, the papers and pleadings 0n file in this action,
13 and upon such further matters that may be presented at the hearing.
14
Dated: October 25 2023
15
16 Respectfully submitted,
17 WEST POINT LEGAL
18
19
Bryan Altman, Efl a
20 Andrew Jung, Esq.
Attorneys for Plaintiff,
21 JASON WHIPPLE
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PLAINTIFF’S MOTION INLIMINE NO. 4
Document Filed Date
October 25, 2023
Case Filing Date
December 16, 2021
Category
Breach of Contract/Warranty Unlimited
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