Request,Application: Lopez Magallon -v - General Motors, LLC et al Print

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     Tionna Dolin (SBN 299010)
     E-mail: tdolin@slpattorney.comr
                                                                          FjLED
     Nino Sanaia (SBN 343765)                                 ‘     PF
     E-mail: nsanaia@slpattorney.com                               SAN           %
     STRATEGIC LEGAL PRACTICES
                                                                                       9n9'
     A PROFESSIONAL CORPORATION
      1888 Century Park East, Floor 19
                                                                         OCT 2       0 lu
     Los Angeles, CA 90067
     Telephone: (310) 929-4900                           BY        Cur
                                                                                                                           im
     Facsimile: (310) 943-3838                                                                   ©

     Attorneys for Plaintiff,
     ALICIA LOPEZ MAGALLON

                        SUPERIOR COURT OF THE STATE OF CALIFORNIA

                                   COUNTY OF SAN BERNARDINO
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     ALICIA LOPEZ MAGALLON,                                       Case No.: CIVSB2111706
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                    Plaintiff,                                    Case Initiated: April 23, 2021
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         vs.                                                      Hon. Gilbert G. Ochoa
14                                                                Dept.: S24
15   GENERAL MOTORS, LLC; and DOES 1
     through 10, inclusive,                                       PLAINTIFF’S MOTIO:                  IN LIMINE NO.
16                                                                4 TO EXCLUDE                EVIDENCE,
                                                                  TESTIMONY OR ARGUMENT
                   Defendants.
17                                                                REFERRING OR RELATING TO
                                                                  PLAINTIFF’S APPLICATION FOR
18                                                                FINANCING            AND     FINANCIAL
                                                                  CONDITION
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                                                                  [Filed Concurrently with Memorandum of
20                                                                Points and Authorities; [Proposed] Order]

21                                                                Complaint Filed: April 23, 2021
                                                                  TRC:                      October 26, 2023
22                                                                Trial Date:               October 30, 2023
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24             TO ALL PARTIES AND THEIR ATTORNEYS                          OF RECORD:

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26             PLEASE   TAKE     NOTICE    that Plaintiff ALICIA            LOPEZ           MAGALLON       (“Plaintiff”)   |

27   hereby moves this Court in limine for an order providing the following:

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        PLAINTIFF’S MOTION            IMINE NO. 4 TO EXCLUDE EVIDENCE, TESTIMONY OR ARGUMENT
         REFERRING      OR RELATING    TO PLAINTIFF’S     APPLICATION                FOR    FINANCING   OR FINANCIAL
                                                   CONDITION
1         Prohibiting       Defendant       GENERAL               MOTORS,         LLC        (“Defendant”)           and

       Defendant's experts, attorneys, and                witnesses from            introducing or attempting to introduce
       (either directly or indirectly) any testimony, evidence                          or argument     referring or relating to
       Plaintiff's application for financing and financial condition.
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                 2.         Prohibiting      Defendant      and   its attorneys          from    introducing     or attempting          to
       introduce any of the above evidence during the trial of the above-entitled action, unless and until
       it is first determined to be admissible in evidence in a hearing held outside the presence and
       hearing of the jury.
                 3          Directing the attorneys for Defendant to instruct Defendant and its witnesses to
       refrain from mentioning or referring to the above-described evidence in the presence or hearing
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       of jurors or prospective jurors; and
ll               4          Directing the attorneys for Defendant to immediately inform Defendant and its
12     witnesses of the terms and effect of the order in limine.
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14               This      Motion   is based on the following               Memorandum            of Points      &     Authorities,      the
15     Declaration        of Tionna       Dolin,   the pleadings      and         records   on   file herein,        and   on   oral    and
16     documentary evidence as may be presented at the hearing on this motion.
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18               Plaintiff advised opposing counsel of Plaintiffs intent to file this motion and initiated a
19     meet and confer effort in good faith with regards to the subject matter of this motion. As of the
20     time     of filing this motion          in limine,     Defendant           has   not responded     to Plaintiff's efforts.

221    (Declaration of Tionna Dolin Paragraph 2, Exhibit                    1).

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       Dated:         October 23, 2023                       STRATEGIC LEGAL PRACTICES, APC
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2.25

26                                                           TIONNA         DOLIN
                                                             Attorney for Plaintiff,
27                                                           ALICIA LOPEZ MAGALLON

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          PLAINTIFF’S MOTION   LIMINE NO. 4 TO EXCLUDE EVIDENCE, TESTIMONY OR ARGUMENT
           REFERRING OR RELATING TO PLAINTIFF’S APPLICATION FOR FINANCING OR FINANCIAL
                                              CONDITION