Motion,Ex Parte: Jarvis, Todd Henry vs. Calder, Robin Elizabeth

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                                1    LAWRENCE D. MILLER, SBN 77448
                    LAW OFFICE OF LAWRENCE D. MILLER                                                               10-28-20
               2    Post Office Box 6107
                    San Mateo, CA       94403
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                    Telephone: (650) 592-9151
               4    lmiller@ldmlawyer.com
               5    Attorney for Defendant, Robin Calder
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               8                          IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
               9                                        IN AND FOR THE COUNTY OF PLACER
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                       TODD HENRY JARVIS,                                              Case No. S-CV-0039929
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             12                Plaintiff,                                              IN LIMINE MOTION NUMBER 3 TO
                                                                                       EXCLUDE EVIDENCE OF AND
             13                 v.                                                     RELATED TO DEFENDANT’S TAX
                                                                                       RETURNS.
             14        ROBIN ELIZABETH CALDER etc.,
             15                                                                        Date: November 9, 2020
                               Defendant.                                              Time: 8:30 a.m.
             16                                                                        Dept: TBA
                                                                                       Complaint Filed: August 23, 2017
             17                                                                        Trial Date: November 9, 2020
             18              Defendant moves this Court for an order excluding evidence of Defendant’s unredacted Income
             19     Tax Returns, including all schedules and all testimony on the subject of the accuracy or inaccuracy of
             20     the data shown of the redacted versions of Defendant’s Schedules E.
             21              Pretrial discovery propounded by Plaintiff sought Defendant’s Schedules E of Defendant’s
             22     federal tax returns. Defendant produced redacted versions of Defendant’s Schedules E for the tax years
             23     2005 through 2018. Defendant’s Schedules E redacted all information from the Schedules other than the
             24     information related to the property that is the subject of this action. Defendant’s tax returns are irrelevant
             25     to the issues raised by this action, other than evidence that Defendant took depreciation on the subject
             26     property on Defendant’s tax returns. The amount of depreciation and the method used to calculate the
             27     depreciation is irrelevant and evidence thereof ought to be excluded.
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             30     _________________________________________________
                     IN LIMINE MOTION [File No. 20-410]
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               1             This motion is based on the Declaration of Robin Calder, the Deposition of Defendant, excerpts
               2    of which will be presented at the hearing; all pleadings, papers, and records in this action; the evidence
               3    presented at the hearing of this matter; the memorandum of points and authorities served and filed
               4    herewith; and such other and further evidence as may be received at the hearing.


                                                                                   Lawrence               D.    Miller
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                     Dated: October 28, 2020                                    _________________________________
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                                                                                LAWRENCE D. MILLER
               7                                                                Attorney for Defendant, Robin Calder

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             30     _________________________________________________
                     IN LIMINE MOTION [File No. 20-410]
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