On March 16, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Urban, Justin,
and
Interstate Electrical Services Corp.,
Weston, Keith,
for Torts
in the District Court of Middlesex County.
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15
COMMONWEALTH OF MASSACHUSETTS
MIDDLESEX, ss. SUPERIOR COURT
C.A. No. 1781CV00814-L2
JUSTIN URBAN,
Plaintiff 2/19/2021
Vv.
RECEIVED
KEITH WESTON and INTERSTATE
ELECTRICIAL SERVICES CORP.,
Defendants
were Ss SSS SS
PLAINTIFF’S MOTION IN LIMINE TO PRECLUDE THE DEFENDANTS FROM
OFFERING EVIDENCE OF OR COMME ING ON ANY ALLEGED OTHER,
UNRELATED DRIVING ACTS OF THE PLAINTIFF
The Plaintiff, Justin Urban, respectfully moves this Court in limine to preclude the
defendants from commenting on or offering evidence of Plaintiff's alleged driving acts unrelated
to the subject incident. Such evidence would be highly prejudicial to the plaintiff and would be
offered only to disingenuously attempt to paint the plaintiff as a careless individual and should
be excluded pursuant to Section 403 and Section 404 of the Massachusetts Guide to Evidence.
Any such alleged unrelated driving acts are wholly irrelevant to the plaintiff's September
12, 2014 accident. The only purpose of introducing evidence of any alleged unrelated bad
driving acts would be to depict the plaintiff as a having a propensity for carelessness or to show
that he does not drive safely. Such evidence is inadmissible. Mass. Guide to Evidence, Section
404 (b); Commonwealth v. Crayton, 470 Mass. 228 (2014).
WHEREFORE, the plaintiff hereby requests this Honorable Court enter a pretrial order
precluding the defendants from offering any evidence or making any argument about plaintiffs
alleged driving acts that are unrelated to the subject incident.Respectfully Submitted,
The Plaintiff,
JUSTIN URBAN,
By his Attorneys,
/s/ Richard J. Sullivan
Richard J. Sullivan, Esq., BBO# 554085
SULLIVAN & SULLIVAN, LLP.
83 Walnut Street
Wellesley, MA 02481
(781) 263-9400
rsullivan: iivantip.com
Dated: February 16, 2021
CERTIFICATE OF SERVICE
I, Richard J. Sullivan, attorney for the plaintiff, hereby certify that I have this day served
the foregoing document to all counsel of record in this action by electronic mail to:
Scott Carroll, Esq.
Stacie Pavao, Esq.
BOYLE SHAUGHNESSY LAW, P.C.
25 Braintree Hill Office Park, Suite 301
Dated:__ February 16, 2021 Attorney:__/s/Richard J. Sullivan
Document Filed Date
February 19, 2021
Case Filing Date
March 16, 2017
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15 COMMONWEALTH OF MASSACHUSETTS MIDDLESEX, ss. SUPERIOR COURT C.A. No. 1781CV00814-L2 JUSTIN URBAN, Plaintiff 2/19/2021 Vv. RECEIVED KEITH WESTON and INTERSTATE ELECTRICIAL SERVICES CORP., Defendants were Ss SSS SS PLAINTIFF’S MOTION IN LIMINE TO PRECLUDE THE DEFENDANTS FROM OFFERING EVIDENCE OF OR COMME ING ON ANY ALLEGED OTHER, UNRELATED DRIVING ACTS OF THE PLAINTIFF The Plaintiff, Justin Urban, respectfully moves this Court in limine to preclude the defendants from commenting on or offering evidence of Plaintiff's alleged driving acts unrelated to the subject incident. Such evidence would be highly prejudicial to the plaintiff and would be offered only to disingenuously attempt to paint the plaintiff as a careless individual and should be excluded pursuant to Section 403 and Section 404 of the Massachusetts Guide to Evidence. Any such alleged unrelated driving acts are wholly irrelevant to the plaintiff's September 12, 2014 accident. The only purpose of introducing evidence of any alleged unrelated bad driving acts would be to depict the plaintiff as a having a propensity for carelessness or to show that he does not drive safely. Such evidence is inadmissible. Mass. Guide to Evidence, Section 404 (b); Commonwealth v. Crayton, 470 Mass. 228 (2014). WHEREFORE, the plaintiff hereby requests this Honorable Court enter a pretrial order precluding the defendants from offering any evidence or making any argument about plaintiffs alleged driving acts that are unrelated to the subject incident.Respectfully Submitted, The Plaintiff, JUSTIN URBAN, By his Attorneys, /s/ Richard J. Sullivan Richard J. Sullivan, Esq., BBO# 554085 SULLIVAN & SULLIVAN, LLP. 83 Walnut Street Wellesley, MA 02481 (781) 263-9400 rsullivan: iivantip.com Dated: February 16, 2021 CERTIFICATE OF SERVICE I, Richard J. Sullivan, attorney for the plaintiff, hereby certify that I have this day served the foregoing document to all counsel of record in this action by electronic mail to: Scott Carroll, Esq. Stacie Pavao, Esq. BOYLE SHAUGHNESSY LAW, P.C. 25 Braintree Hill Office Park, Suite 301 Dated:__ February 16, 2021 Attorney:__/s/Richard J. Sullivan