On February 17, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Mora, Elda,
and
Ma, Candy D,
for Auto PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
ELECTRONICALLY FIL ED (Auto)
SUPERIOR COURT OF CALIFORNIA
John C. Hatch (SBN 31 1754) COUNTY 0|: SAN BER \JARDINO
Blanca Anselmo (SBN 326538) 1/4/2024 5:51 PM
INJURY LEGAL CENTER, P.C.
2062 Business Center Drive, Suite 200
Irvine, CA 92612
KOOONGUI-bUJNr—t
Telephone: (949) 756-9300
Facsimile: (888) 330-5773
Attorneys for Plaintiff
ELDA MORA
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
UNLIMITED JURISDICTION
ELDA MQRA Case N0. CIVSB2 1 025 14
. PLAINTIFF’S MOTION IN LIMINE T0
P 1 am“.ff a
EXCLUDE EVIDENCE 0F HEALTH
INSURANCE 0R MEDICARE
vs. REIMBURSEMENT RATES T0
DISCOUNT PLAINTIFF’S FUTURE
CANDY D. MA; and DOES 1 to 20, inclusive,
MEDICAL EXPENSES [MIL NO- 3]
Hon. Donald Alvarez
Defendants. Dept. 823
NNNNNNNNNr—tr—th—Ab—Ar—tr—tr—Ab—Ab—Ar—t
Complaint Filed: February 17, 2021
Trial Date: January 17, 2024
OOQONUIJ>UJNHO©OOQQKIl¥WNHO
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD HEREIN:
PLEASE TAKE NOTICE that Plaintiff ELDA MORA Will move this Court for an
issuance 0f the following orders in limine:
1) An order excluding any and all evidence 0f health insurance 0r Medicare reimbursement
rates t0 discount Plaintiffs’ past and future medical care; and
2) An order requiring the attorneys for all parties to instruct their Witnesses of the court's
exclusionary order 0n this motion; and
1
MOTION IN LIMINE TO EXCLUDE EVIDENCE OF HEALTH INSURANCE OR MEDICARE
PLAINTIFF’S
REIMBURSEMENT RATES TO DISCOUNT PLAINTIFF’S FUTURE MEDICAL EXPENSES [MIL NO. 3]
3) An order requiring the attorney for Defendant, prior to making any references, comments, or
assertions concerning such matters, to approach the bench and make an offer of proof to the
court so that the court, prior to any presentation ofthe above-referenced evidence t0 the jury,
can make a preliminary determination 0f the relevancy and admissibility thereof.
KOOONGUI-bUJNr—t
This motion is made and based California Evidence Code section 350 and 352. The motion
is further based upon the supporting Memorandum of Points and Authorities, the pleadings and
papers on file in this action, and upon such argument and evidence as may be presented prior to
0r at the hearing 0f this matter.
Dated: January 4, 2024 INJURY LEGAL CENTER, P.C.
By: @O:
Joh C. Hatch, Esq.
l
At omeys for Plaintiff,
ELDA MORA
NNNNNNNNNr—tr—th—Ab—Ar—tr—tr—Ab—Ab—Ar—t
OOQONUIJ>UJNHO©OOQQKIl¥WNHO
2
PLAINTIFF’S MOTION IN LIMINE TO EXCLUDE EVIDENCE OF HEALTH INSURANCE OR MEDICARE
REIMBURSEMENT RATES TO DISCOUNT PLAINTIFF’S FUTURE MEDICAL EXPENSES [MIL NO. 3]
Document Filed Date
January 04, 2024
Case Filing Date
February 17, 2021
Category
Auto PI/PD/WD Unlimited
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ELECTRONICALLY FIL ED (Auto) SUPERIOR COURT OF CALIFORNIA John C. Hatch (SBN 31 1754) COUNTY 0|: SAN BER \JARDINO Blanca Anselmo (SBN 326538) 1/4/2024 5:51 PM INJURY LEGAL CENTER, P.C. 2062 Business Center Drive, Suite 200 Irvine, CA 92612 KOOONGUI-bUJNr—t Telephone: (949) 756-9300 Facsimile: (888) 330-5773 Attorneys for Plaintiff ELDA MORA SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO UNLIMITED JURISDICTION ELDA MQRA Case N0. CIVSB2 1 025 14 . PLAINTIFF’S MOTION IN LIMINE T0 P 1 am“.ff a EXCLUDE EVIDENCE 0F HEALTH INSURANCE 0R MEDICARE vs. REIMBURSEMENT RATES T0 DISCOUNT PLAINTIFF’S FUTURE CANDY D. MA; and DOES 1 to 20, inclusive, MEDICAL EXPENSES [MIL NO- 3] Hon. Donald Alvarez Defendants. Dept. 823 NNNNNNNNNr—tr—th—Ab—Ar—tr—tr—Ab—Ab—Ar—t Complaint Filed: February 17, 2021 Trial Date: January 17, 2024 OOQONUIJ>UJNHO©OOQQKIl¥WNHO TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD HEREIN: PLEASE TAKE NOTICE that Plaintiff ELDA MORA Will move this Court for an issuance 0f the following orders in limine: 1) An order excluding any and all evidence 0f health insurance 0r Medicare reimbursement rates t0 discount Plaintiffs’ past and future medical care; and 2) An order requiring the attorneys for all parties to instruct their Witnesses of the court's exclusionary order 0n this motion; and 1 MOTION IN LIMINE TO EXCLUDE EVIDENCE OF HEALTH INSURANCE OR MEDICARE PLAINTIFF’S REIMBURSEMENT RATES TO DISCOUNT PLAINTIFF’S FUTURE MEDICAL EXPENSES [MIL NO. 3] 3) An order requiring the attorney for Defendant, prior to making any references, comments, or assertions concerning such matters, to approach the bench and make an offer of proof to the court so that the court, prior to any presentation ofthe above-referenced evidence t0 the jury, can make a preliminary determination 0f the relevancy and admissibility thereof. KOOONGUI-bUJNr—t This motion is made and based California Evidence Code section 350 and 352. The motion is further based upon the supporting Memorandum of Points and Authorities, the pleadings and papers on file in this action, and upon such argument and evidence as may be presented prior to 0r at the hearing 0f this matter. Dated: January 4, 2024 INJURY LEGAL CENTER, P.C. By: @O: Joh C. Hatch, Esq. l At omeys for Plaintiff, ELDA MORA NNNNNNNNNr—tr—th—Ab—Ar—tr—tr—Ab—Ab—Ar—t OOQONUIJ>UJNHO©OOQQKIl¥WNHO 2 PLAINTIFF’S MOTION IN LIMINE TO EXCLUDE EVIDENCE OF HEALTH INSURANCE OR MEDICARE REIMBURSEMENT RATES TO DISCOUNT PLAINTIFF’S FUTURE MEDICAL EXPENSES [MIL NO. 3]