On January 21, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Luciano, Jimmy,
Vicario, Nina,
and
Does 1-10,
General Motors Llc, A Delaware Limited Liability Company,
for Breach of Contract/Warranty Unlimited
in the District Court of San Bernardino County.
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QUILL & ARROW, LLP
ELECTRONICALLY FILED (Auto)
Kevin Y. Jacobson, Esq. (SBN 320532)
SUPERIOR COURT OF CA .LIFORNIA
kiacobson@quillarr0wlaw.com COUNTY OF SAN BERNAF RDINO
Harry H. Terzian, Esq. (SBN 347701) 1/1 8/2024 6:01 PM
hterzian@quillarr0wlaw.com
Matthew Treybig, Esq. (SBN 336797)
mtrevbig@quillarrowlaw.com
Nicholas Yowarski, Esq (SBN 338165)
nvowarski@quillarrowlaw.com
David Derderian, Esq. (SBN 349787)
dderderian@quillarrowlaw.com
Chris Grigoryan, Esq. (SBN 349424)
cgrigorvanQunillarrowlaw.com
10900 Wilshire B1Vd., Suite 300
Los Angeles, CA 90024
Telephone: (3 10) 933-4271
10 Facsimile: (3 10) 889—0645
11 Attorneys for Plaintiffs,
NINA VICARIO
12 AND JIMMY LUCIANO
13
14
SUPERIOR COURT OF CALIFORNIA
15
COUNTY OF SAN BERNARDINO
16 NINA VICARIO, an individual, and JIMMY Case No.: CIVSBZ 1 02007
LUCIANO, an individual,
Assigned t0 the Hon. Gilbert Ochoa in Dept.
17
S24
Plaintiffs,
18
VS.
PLAINTIFFS’ MOTION IN LIMINE
NO. 9 0f 10
19
GENERAL MOTORS LLC, a Delaware
NOTICE OF MOTION AND MOTION
20
Limited Liability Company, and DOES 1
INLIMINE TO PROHIBIT
through 10, inclusive,
TESTIMONY OR EVIDENCE NOT
21
PREVIOUSLY IDENTIFIED OR
CONTAINED WITHIN DEFENDANT’S
22
FORMAL DISCOVERY RESPONSES
Defendant.
23
Date Filed: January 21, 2021
24 Trial Date: January 29, 2024
25
26
27
28
-1-
PLAINTIFFS’ MOTION INLIMINE NO. 9
TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that Plaintiffs NINA VICARIO and JIMMY LUCIANO
(“Plaintiffs”) move the Court in limine for an order preventing Defendant from offering testimony
0r evidence not previously identified 0r contained within Defendant’s discovery responses.
Plaintiffs further move 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 to convey to the jury, directly or indirectly, any of the facts
mentioned in this Motion without first obtaining permission from the Court outside the presence
and hearing 0f the jury;
10 2. Not to make any reference to the fact that this Motion has been filed; and,
11 3. T0 warn and caution all Witnesses to strictly follow the same instructions.
12 This motion is based upon the supporting Memorandum 0f Points and Authorities, the
13 Declaration of Nicholas Yowarski, Esq. attached hereto, the papers and pleadings 0n file in this
14 action, and upon such further matters that may be presented at the hearing.
15 Plaintiffs advised opposing counsel 0ftheir intent t0 file this Motion and attempted t0 meet
16 and confer in good faith with regards t0 the subject matter 0f this Motion 0n January 17, 2024.
17
Dated: Januagy 17, 2024
18
19 Respectfully submitted,
20 QUILL & ARROW, LLP
21
22 Kevi .Uacobson, Esq.
Janua 17, 2024Nicholas Yowarski, Esq.
23 Attorneys for Plaintiffs,
NINA VICARIO
24 AND JIMMY LUCIANO
25
26
27
28
-2-
PLAINTIFFS’ MOTION INLIMINE NO. 9
Document Filed Date
January 18, 2024
Case Filing Date
January 21, 2021
Category
Breach of Contract/Warranty Unlimited
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