On January 24, 2020 a
Motion-Secondary
was filed
involving a dispute between
Williams, Barbara,
and
Maldonado, Mariclare,
Wilson, Troy,
for Personal Injury Motor Vehicle Unlimited
in the District Court of San Bernardino County.
Preview
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1 McClaugherty & Associates ELECTRONICALLY FILED (Auto)
Jay S. McClaugherty (State Bar No. 99063) SUPERIOR COURT OF CALIFORNIA
2 Email: jay.mcclaugherty(mcctria1s.com COUNTY OF SAN BERNARDINO
Hayden T. Traver (State Bar No. 317428) 12/6/2023 3:47 PM
3 Email: hayden.traver@mcctrials.com
222 East Huntington Drive, Suite 230
4 Monrovia, California 91016
Telephone: (626) 821-1100
5 Fax: (626) 821-2626
6 Attorneys for Defendants
TROY WILSON and MARICLARE MALDONADO
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF SAN BERNARDINO - CENTRAL DISTRICT
10
BARBARA WILLIAMS, an individual, Case No.: C1VDS2002655
[Unlimited Jurisdiction]
12 Plaintiff,
DEFENDANTS’ OPPOSITION TO
13 v. PLAINTIFF’S MOTION IN LIMINE NO.
THREE
14 TROY WILSON; MARICLARE
MALDONADO; and DOES 1 through 100, Trial:
15 Inclusive, Date: December 11, 2023
Time: 10:00a.m.
16 Defendants. Dept.: S37
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DEFENDANTS OPPOSITION TO PLAINTIFF’S MOTION TN LIMINE NO. 3
_
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1 I.
2 ARGUMENTS AND AUTHORITIES
3 A. Defendant Timely Designated a Medical Billing and Life Care Expert
4 Plaintiff BARBARA WILLIAMS’ (“Plaintiff’) Motion in Limine No. Three states that
5 states that “Defendants have failed to disclose any medical billing expert that may provide expert
6 opinions as to Plaintiffs past and future medical costs.” This is completely inaccurate.
7 Defendants TROY WILSON and MARICLARE MALDONADO (“Ms. Maldonado”)
8 (collectively, “Defendants”) designated Mary Jesko (“Ms. Jesko”) as Defendants’ medical billing
9 expert and life care planner. (See Declaration of Hayden T. Traver, hereafter Traver DecI. ¶ 2).
10 Ms. Jesko’s designation states that she “reviewed Plaintiffs medical billing records and evaluated
11 the medical care fees, coding and insurance requirements, and receipts to determine whether those
12 rates are within the usual customary, and reasonable raters.” (Id.). Ms. Jesko’s designation also
13 states that she will “evaluate the reasonable value of future medical costs in life care plans.” (Id.).
14 There is no dispute that Defendants timely designated experts in this case. Defendants are
15 permitted to present Ms. Jesko’s testimony at trial. The Court should deny Plaintiffs motion in
16 lirnine.
17 II.
18 CONCLUSION
19 Defendants respectfully requests that the Court deny Plaintiffs Motion in Limine No. 3.
20
21 DATED: December 4, 2023 MCCLA GHERTY & ASSOCIATES
23 By:
ayden Traver
.
24 Attorney for Defendants
TROY WILSON and
Li
MARICLARE MALDONADO
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DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION IN LIMINE NO. 3
Document Filed Date
December 06, 2023
Case Filing Date
January 24, 2020
Category
Personal Injury Motor Vehicle Unlimited
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__________________________________ 1 McClaugherty & Associates ELECTRONICALLY FILED (Auto) Jay S. McClaugherty (State Bar No. 99063) SUPERIOR COURT OF CALIFORNIA 2 Email: jay.mcclaugherty(mcctria1s.com COUNTY OF SAN BERNARDINO Hayden T. Traver (State Bar No. 317428) 12/6/2023 3:47 PM 3 Email: hayden.traver@mcctrials.com 222 East Huntington Drive, Suite 230 4 Monrovia, California 91016 Telephone: (626) 821-1100 5 Fax: (626) 821-2626 6 Attorneys for Defendants TROY WILSON and MARICLARE MALDONADO 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF SAN BERNARDINO - CENTRAL DISTRICT 10 BARBARA WILLIAMS, an individual, Case No.: C1VDS2002655 [Unlimited Jurisdiction] 12 Plaintiff, DEFENDANTS’ OPPOSITION TO 13 v. PLAINTIFF’S MOTION IN LIMINE NO. THREE 14 TROY WILSON; MARICLARE MALDONADO; and DOES 1 through 100, Trial: 15 Inclusive, Date: December 11, 2023 Time: 10:00a.m. 16 Defendants. Dept.: S37 17 18 19 20 21 22 23 24 25 26 27 28 —1— DEFENDANTS OPPOSITION TO PLAINTIFF’S MOTION TN LIMINE NO. 3 _ _____ 1 I. 2 ARGUMENTS AND AUTHORITIES 3 A. Defendant Timely Designated a Medical Billing and Life Care Expert 4 Plaintiff BARBARA WILLIAMS’ (“Plaintiff’) Motion in Limine No. Three states that 5 states that “Defendants have failed to disclose any medical billing expert that may provide expert 6 opinions as to Plaintiffs past and future medical costs.” This is completely inaccurate. 7 Defendants TROY WILSON and MARICLARE MALDONADO (“Ms. Maldonado”) 8 (collectively, “Defendants”) designated Mary Jesko (“Ms. Jesko”) as Defendants’ medical billing 9 expert and life care planner. (See Declaration of Hayden T. Traver, hereafter Traver DecI. ¶ 2). 10 Ms. Jesko’s designation states that she “reviewed Plaintiffs medical billing records and evaluated 11 the medical care fees, coding and insurance requirements, and receipts to determine whether those 12 rates are within the usual customary, and reasonable raters.” (Id.). Ms. Jesko’s designation also 13 states that she will “evaluate the reasonable value of future medical costs in life care plans.” (Id.). 14 There is no dispute that Defendants timely designated experts in this case. Defendants are 15 permitted to present Ms. Jesko’s testimony at trial. The Court should deny Plaintiffs motion in 16 lirnine. 17 II. 18 CONCLUSION 19 Defendants respectfully requests that the Court deny Plaintiffs Motion in Limine No. 3. 20 21 DATED: December 4, 2023 MCCLA GHERTY & ASSOCIATES 23 By: ayden Traver . 24 Attorney for Defendants TROY WILSON and Li MARICLARE MALDONADO 26 27 28 -2- DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION IN LIMINE NO. 3