On April 17, 2018 a
Proof of Service
was filed
involving a dispute between
Trujillo, Bryan,
Trujillo, Cindy,
and
Does 1-20,
Does 1-50,
Magee, Stephen,
Sac Aero Flying Club, Inc.,
for (23) Unlimited Other PI/PD/WD
in the District Court of San Mateo County.
Preview
MICHAEL S. DANKO, ESQ. SBN 111359
mdanko@dankolaw.com
DANKO MEREDITH Electronically
333 Twin Dolphin Drive, Suite 145 F||_E
Redwood Shores, CA 94065 by Superlor Court of Calll‘m‘n Ia,C&unt:.I ofSan Ham
Telephgne: (650) 453-3600 UN 2/26/2021
Fac51mlle: (650) 394-8672
Er m; Joel Lacey,
Deputyfrerk
Attorneys for Plaintiffs
BRYAN TRUJILLO and CINDY TRUJILLO
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN MATEO
UNLIMITED CIVIL JURISDICTION
BRYAN TRUJILLO and CINDY TRUJILLO, Case No. 18CIV01901
Plaintiffs, PROOF OF SERVICE
v. Plaintiffs’ Motions in Limine
STEPHEN MAGEE, SAC AERO FLYING Date: March 8, 2021
CLUB, INC., AND DOES 1 - 50, Time: 1:30 pm.
Dept.: 4
Defendants
Complaint led: April l7, 2018
I, the undersigned, declare:
I am employed in the County ofSan Mateo, State of California. I am over the age of eighteen
and not a party to this action. My business address is 333 Twin Dolphin Drive, Suite 145, Redwood
Shores, CA 94065. On February ll, 2021, I served the foregoing documents:
PLAINTIFFS’ NOTICE OF MOTION AND MOTION IN LIMINE NO. l TO EXCLUDE
DEFENDANTS’ APPRAISER EXPERT TED FARAVELLI; MEMORANDUM OF POINTS
AND AUTHORITIES IN SUPPORT; DECLARATION IN SUPPORT.
PLAINTIFFS’ NOTICE OF MOTION AND MOTION IN LIMINE NO. 2 TO EXCLUDE
DEFENDANTS’ EXPERT JAMES PURPURA; MEMORANDUM OF POINTS AND
AUTHORITIES IN SUPPORT; DECLARATION IN SUPPORT.
l
PROOF OF SERVICE
Plaintiffs’ Motions in Limine
PLAINTIFFS’ NOTICE OF MOTION AND MOTION IN LIMINE NO. 3 TO EXCLUDE
DEFENDANTS’ EXPERT RICK RAILSBACK; MEMORANDUM OF POINTS AND
AUTHORITIES IN SUPPORT; DECLARATION IN SUPPORT.
PLAINTIFFS’ NOTICE OF MOTION AND MOTION IN LIMINE NO. 4 TO EXCLUDE
DEFENDANT STEPHEN MAGEE FROM TESTIFYING THAT HE EXPERIENCED WIND
SHEAR; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT;
DECLARATION IN SUPPORT.
PLAINTIFFS’ NOTICE OF MOTION AND MOTION IN LIMINE NO. 5 TO EXCLUDE
CERTAIN TESTIMONY OF DEFENDANTS’ EXPERT BARRY SCHIFF; MEMORANDUM
OF POINTS AND AUTHORITIES IN SUPPORT; DECLARATION IN SUPPORT.
PLAINTIFFS’ NOTICE OF MOTION AND MOTION IN LIMINE NO. 6 TO EXCLUDE
TESTIMONY RE DEFENDANTS’ EXPERT BARRY SCHIFF’S UNDISCLOSED FLIGHT
TESTING; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT;
DECLARATION IN SUPPORT.
PLAINTIFFS’ NOTICE OF MOTION AND MOTION IN LIMINE NO. 7 TO EXCLUDE
EVIDENCE OR OPINION REGARDING THE COMPARATIVE FAULT OF PLAINTIFFS;
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT; DECLARATION IN
SUPPORT.
PLAINTIFFS’ NOTICE OF MOTION AND MOTION INLIMINE NO. 8 TO EXCLUDE
EVIDENCE REGARDING PAYMENTS BY INSURERS; MEMORANDUM OF POINTS AND
AUTHORITIES IN SUPPORT.
PLAINTIFFS’ NOTICE OF MOTION AND MOTION IN LIMINE NO. 9 TO EXCLUDE
EVIDENCE AND DEMONSTRATIVES REGARDING WHERE PLAINTIFFS STAYED
WHEN FORCED FROM THEIR HOME; MEMORANDUM OF POINTS AND
AUTHORITIES IN SUPPORT.
on the party(ies) to this action, as follows, in the manner described below:
Garry L. Montanari, Esq. Attorneysfor Defendant
Wesley S. Wenig, Esq. STEPHEN WGEE and SAC AERO FL YING
John H. Moon, Esq. .
CLUB, INC.
Michaelis, Montanari & Johnson, P.C.
4333 Park Terrace Drive, Suite 110
Westlake Village, CA 91361
Ph: (818) 865-0444
Fx: (818) 865-8444
montanari mm'lawnet
wsweni2@mmilaw.net
imoon@mmilaw.net
D BY U.S. MAIL -I enclosed the documents in a sealed envelope or package addressed
to the persons at the address(es) below and (speci/ one):
D deposited the sealed envelope with the U.S. Postal Service, with postage fully
2
PROOF OF SERVICE
Plaintiffs’ Motions in Limine
prepaid.
D placed the envelope for collection and mailing, following our ordinary business
practices. I am readily familiar with this business’s practice for collecting and
processing correspondence for mailing. On the same day that correspondence is
placed for collection and mailing, it is deposited in the ordinary course of
business with the U.S. Postal Service, in a sealed envelope with postage fully
prepaid.
X BY ELECTRONIC SERVICE —I caused the document(s) to be sent to the persons at the
electronic service address(es) listed above.
I declare under penalty of perj ury that the foregoing is true and correct. Executed on
February 26, 2021 , at Redwood Shores, California.
$2M!— Fusi Hokafonu
3
PROOF OF SERVICE
Plaintiffs’ Motions in Limine
Document Filed Date
February 26, 2021
Case Filing Date
April 17, 2018
Category
(23) Unlimited Other PI/PD/WD
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MICHAEL S. DANKO, ESQ. SBN 111359 mdanko@dankolaw.com DANKO MEREDITH Electronically 333 Twin Dolphin Drive, Suite 145 F||_E Redwood Shores, CA 94065 by Superlor Court of Calll‘m‘n Ia,C&unt:.I ofSan Ham Telephgne: (650) 453-3600 UN 2/26/2021 Fac51mlle: (650) 394-8672 Er m; Joel Lacey, Deputyfrerk Attorneys for Plaintiffs BRYAN TRUJILLO and CINDY TRUJILLO SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN MATEO UNLIMITED CIVIL JURISDICTION BRYAN TRUJILLO and CINDY TRUJILLO, Case No. 18CIV01901 Plaintiffs, PROOF OF SERVICE v. Plaintiffs’ Motions in Limine STEPHEN MAGEE, SAC AERO FLYING Date: March 8, 2021 CLUB, INC., AND DOES 1 - 50, Time: 1:30 pm. Dept.: 4 Defendants Complaint led: April l7, 2018 I, the undersigned, declare: I am employed in the County ofSan Mateo, State of California. I am over the age of eighteen and not a party to this action. My business address is 333 Twin Dolphin Drive, Suite 145, Redwood Shores, CA 94065. On February ll, 2021, I served the foregoing documents: PLAINTIFFS’ NOTICE OF MOTION AND MOTION IN LIMINE NO. l TO EXCLUDE DEFENDANTS’ APPRAISER EXPERT TED FARAVELLI; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT; DECLARATION IN SUPPORT. PLAINTIFFS’ NOTICE OF MOTION AND MOTION IN LIMINE NO. 2 TO EXCLUDE DEFENDANTS’ EXPERT JAMES PURPURA; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT; DECLARATION IN SUPPORT. l PROOF OF SERVICE Plaintiffs’ Motions in Limine PLAINTIFFS’ NOTICE OF MOTION AND MOTION IN LIMINE NO. 3 TO EXCLUDE DEFENDANTS’ EXPERT RICK RAILSBACK; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT; DECLARATION IN SUPPORT. PLAINTIFFS’ NOTICE OF MOTION AND MOTION IN LIMINE NO. 4 TO EXCLUDE DEFENDANT STEPHEN MAGEE FROM TESTIFYING THAT HE EXPERIENCED WIND SHEAR; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT; DECLARATION IN SUPPORT. PLAINTIFFS’ NOTICE OF MOTION AND MOTION IN LIMINE NO. 5 TO EXCLUDE CERTAIN TESTIMONY OF DEFENDANTS’ EXPERT BARRY SCHIFF; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT; DECLARATION IN SUPPORT. PLAINTIFFS’ NOTICE OF MOTION AND MOTION IN LIMINE NO. 6 TO EXCLUDE TESTIMONY RE DEFENDANTS’ EXPERT BARRY SCHIFF’S UNDISCLOSED FLIGHT TESTING; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT; DECLARATION IN SUPPORT. PLAINTIFFS’ NOTICE OF MOTION AND MOTION IN LIMINE NO. 7 TO EXCLUDE EVIDENCE OR OPINION REGARDING THE COMPARATIVE FAULT OF PLAINTIFFS; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT; DECLARATION IN SUPPORT. PLAINTIFFS’ NOTICE OF MOTION AND MOTION INLIMINE NO. 8 TO EXCLUDE EVIDENCE REGARDING PAYMENTS BY INSURERS; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT. PLAINTIFFS’ NOTICE OF MOTION AND MOTION IN LIMINE NO. 9 TO EXCLUDE EVIDENCE AND DEMONSTRATIVES REGARDING WHERE PLAINTIFFS STAYED WHEN FORCED FROM THEIR HOME; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT. on the party(ies) to this action, as follows, in the manner described below: Garry L. Montanari, Esq. Attorneysfor Defendant Wesley S. Wenig, Esq. STEPHEN WGEE and SAC AERO FL YING John H. Moon, Esq. . CLUB, INC. Michaelis, Montanari & Johnson, P.C. 4333 Park Terrace Drive, Suite 110 Westlake Village, CA 91361 Ph: (818) 865-0444 Fx: (818) 865-8444 montanari mm'lawnet wsweni2@mmilaw.net imoon@mmilaw.net D BY U.S. MAIL -I enclosed the documents in a sealed envelope or package addressed to the persons at the address(es) below and (speci/ one): D deposited the sealed envelope with the U.S. Postal Service, with postage fully 2 PROOF OF SERVICE Plaintiffs’ Motions in Limine prepaid. D placed the envelope for collection and mailing, following our ordinary business practices. I am readily familiar with this business’s practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the U.S. Postal Service, in a sealed envelope with postage fully prepaid. X BY ELECTRONIC SERVICE —I caused the document(s) to be sent to the persons at the electronic service address(es) listed above. I declare under penalty of perj ury that the foregoing is true and correct. Executed on February 26, 2021 , at Redwood Shores, California. $2M!— Fusi Hokafonu 3 PROOF OF SERVICE Plaintiffs’ Motions in Limine