On April 23, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Lopez Magallon, Alicia,
and
Does 1-10,
General Motors, Llc,
for Breach of Contract/Warranty Unlimited
in the District Court of San Bernardino County.
Preview
\a A3 ,R:
n
G n Kpum‘fi y
Tionna Dolin (SBN 299010)
E-mail: Idolin/(Dslpattomeycom
Nino Sanaia (SBN 343765)
E-mail: nsanaiafislpattomey£0m :L E: u
4h. .‘M‘Ww «1:19 w -
STRATEGIC LEGAL PRACTICES (IWUNH "2 2‘“
A PROFESSIONAL CORPORATION slew n‘fiwn x
I888 Century Park East, Floor l9
Los Angeles. CA 90067 OCT 2 3 2823
Telephone: (3 0) 929-4900
l
Facsimile: (310) 943-3838
Attorneys for Plaintiff,
BY M1; 331d
’NIerr:
L
'77: w
4*,
-: ,
.-/
ALICIA LOPEZ MAGALLON
OOOONQ
SUPERIOR COURT 0F THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO aaxvd
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ALICIA LOPEZ MAGALLON, Case No.2 CIVSBZI l I706
l2
Plaintiff, Case Initiated: April 23, 2021
l3
vs. Hon. Gilbert G. Ochoa
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Dept.: $24
GENERAL MOTORS, LLC; and DOES 1
through 10, inclusive, PLAINTIFF’SMOTION IN LIMINE NO.
l6 3 TO EXCLUDE EVIDENCE OR
Defendants. ARGUMENT REFERRING OR
l7 RELATING TO ATTORNEY’S FEES
AND LITIGATION COSTS
l8
[Filed Concurrently with Memorandum of
l9
Points and Authorities; [Proposed] Order]
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Complaint Filed: April 23, 2021
21 TRC: October 26, 2023
Trial Date: October 30, 2023
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TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
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PLEASE TAKE NOTICE that PlaintiffALICIA LOPEZ MAGALLON (“Plaintiff”)
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hereby moves this Court in limine for an order to exclude evidence or argument referring or
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relating t0 attomey’s fees and litigation costs.
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PLAINTIFF’S MOTION [N LIMINE N0. 3 TO EXCLUDE EVIDENCE OR ARGUMENT REFERRING OR
RELATING TO ATTORNEY’S FEES AND LITIGATION COSTS
This motion is made on the grounds that evidence of attomey‘s fees and litigation costs
is not relevant and would be unduly prejudicial t0 Plaintiff.
This Motion is based on the following Memorandum of Points & Authorities. the
Declaration of Tionna Dolin, the pleadings and records on file herein, and 0n oral and
documentary evidence as may be presented at the hearing on this motion.
Plaintiff advised opposing counsel of Plaintiff‘s intent to file this motion and initiated a
OOOOQO
meet and confer effort in good faith with regards to the subject matter of this motion. As of the
time of filing this motion in Iimine, Defendant has not responded to Plaintiff‘s efforts.
(Declaration ofTionna Dolin Paragraph 2. Exhibit 1).
ll
12 Dated: October 23. 2023 STRATEGIC LEGAL PRACTICES, APC
l4
By'
15
TIONNA DOLIN
l6 Attorney for Plaintiff.
ALICIA LOPEZ MAGALLON
l7
l8
l9
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PLAINTIFF’S MOTION IN LIMINE NO. 3 TO EXCLUDE EVIDENCE OR ARGUMENT REFERRING OR
RELATING TO ATTORNEY’S FEES AND LITIGATION COSTS
Document Filed Date
October 23, 2023
Case Filing Date
April 23, 2021
Category
Breach of Contract/Warranty Unlimited
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\a A3 ,R: n G n Kpum‘fi y Tionna Dolin (SBN 299010) E-mail: Idolin/(Dslpattomeycom Nino Sanaia (SBN 343765) E-mail: nsanaiafislpattomey£0m :L E: u 4h. .‘M‘Ww «1:19 w - STRATEGIC LEGAL PRACTICES (IWUNH "2 2‘“ A PROFESSIONAL CORPORATION slew n‘fiwn x I888 Century Park East, Floor l9 Los Angeles. CA 90067 OCT 2 3 2823 Telephone: (3 0) 929-4900 l Facsimile: (310) 943-3838 Attorneys for Plaintiff, BY M1; 331d ’NIerr: L '77: w 4*, -: , .-/ ALICIA LOPEZ MAGALLON OOOONQ SUPERIOR COURT 0F THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO aaxvd ll ALICIA LOPEZ MAGALLON, Case No.2 CIVSBZI l I706 l2 Plaintiff, Case Initiated: April 23, 2021 l3 vs. Hon. Gilbert G. Ochoa l4 Dept.: $24 GENERAL MOTORS, LLC; and DOES 1 through 10, inclusive, PLAINTIFF’SMOTION IN LIMINE NO. l6 3 TO EXCLUDE EVIDENCE OR Defendants. ARGUMENT REFERRING OR l7 RELATING TO ATTORNEY’S FEES AND LITIGATION COSTS l8 [Filed Concurrently with Memorandum of l9 Points and Authorities; [Proposed] Order] 20 Complaint Filed: April 23, 2021 21 TRC: October 26, 2023 Trial Date: October 30, 2023 22 23 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 24 25 PLEASE TAKE NOTICE that PlaintiffALICIA LOPEZ MAGALLON (“Plaintiff”) 26 hereby moves this Court in limine for an order to exclude evidence or argument referring or 27 relating t0 attomey’s fees and litigation costs. 28 PLAINTIFF’S MOTION [N LIMINE N0. 3 TO EXCLUDE EVIDENCE OR ARGUMENT REFERRING OR RELATING TO ATTORNEY’S FEES AND LITIGATION COSTS This motion is made on the grounds that evidence of attomey‘s fees and litigation costs is not relevant and would be unduly prejudicial t0 Plaintiff. This Motion is based on the following Memorandum of Points & Authorities. the Declaration of Tionna Dolin, the pleadings and records on file herein, and 0n oral and documentary evidence as may be presented at the hearing on this motion. Plaintiff advised opposing counsel of Plaintiff‘s intent to file this motion and initiated a OOOOQO meet and confer effort in good faith with regards to the subject matter of this motion. As of the time of filing this motion in Iimine, Defendant has not responded to Plaintiff‘s efforts. (Declaration ofTionna Dolin Paragraph 2. Exhibit 1). ll 12 Dated: October 23. 2023 STRATEGIC LEGAL PRACTICES, APC l4 By' 15 TIONNA DOLIN l6 Attorney for Plaintiff. ALICIA LOPEZ MAGALLON l7 l8 l9 20 21 22 23 24 25 26 27 28 PLAINTIFF’S MOTION IN LIMINE NO. 3 TO EXCLUDE EVIDENCE OR ARGUMENT REFERRING OR RELATING TO ATTORNEY’S FEES AND LITIGATION COSTS