Motion_in_limine_opp_plts_mil_2MotionCal. Super. - 2nd Dist.February 23, 2017Electronically FILED by Superior Court of California, County of Los Angeles on 03/13/2019 12:06 AM Sherri R. Carter, Executive Officer/Clerk of Court, by A. Trinh,Deputy Clerk © 0 2 ON Wn B A W ND N N N N N N N N N mm e m e m e t e m p m e d pe ee c o ~~ S N nm BRA W N = DO O N Y nn Re W N =e Oo JAMES J. PERKINS (SBN 126163) BRAD A. BYSZEWSKI (SBN 238527) COLMAN LAW GROUP 500 North Brand Boulevard, Suite 2200 Glendale, California 91203 TELEPHONE (818)546-8686 FACSIMILE (818)546-8787 Attorneys for Defendant APRO, LLC (erroneously sued and served as CF United, LLC) SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES - SPRING STREET COURTHOUSE ROSARIO MIRANDA AND JAMES Case No.: BC651713 GONZALEZ, Complaint Filed: 02/27/2017 Plaintiffs, [Unlimited Civil Jurisdiction - Demand exceeds $25,000] VS. DEFENDANT’S OPPOSITION TO CF UNITED, LLC; PHILLIPS 66 PLAINTIFFS’ MOTION IN LIMINE NO. 2 COMPANY; 76 GASOLINE STATION TO EXCLUDE AND/OR PRECLUDE ANY AND MARKET AND DOES 1 THROUGH MENTION OF OR REFERENCE TO 100, INCLUSIVE, PLAINTIFF ROSARIO MIRANDA'’S MEDICAL TREATMENT BEING ON A Defendants. LIEN BASIS OR ATTORNEY-REFERRED TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that defendant APRO, LLC (erroneously sued and served as CF United, LLC) (“Defendant”) hereby submits this Opposition to Plaintiffs’ Motion in Limine Number 2 to exclude and/or preclude any mention of or reference to Plaintiff Rosario Miranda’s medical treatment being on a lien basis or attorney-referred. I" 1 1 1 DEFENDANT'S OPPOSITION TO PLAINTIFFS” MOTION IN LIMINE NO. 2 TO EXCLUDE AND/OR PRECLUDE ANY MENTION OF OR REFERENCE TO PLAINTIFF ROSARIO MIRANDA’S MEDICAL TREATMENT BEING ON A LIEN BASIS OR ATTORNEY-REFERRED © © JI a Ww» BA WwW N = N N N N N N N N N = m m E e e e e 0 JI O N Wn RA W I N D R O LO N N N R W = O This motion is based upon the attached Memorandum of Points and Authorities, the pleadings and papers on file in this action, and upon such oral or documentary evidence as may be presented at the hearing of this matter. Dated: March 12, 2019 COLMAN L GROUP JAMES J. PERKINS BRAD A. BYSZEWSKI Attorneys for Defendant APRO, LLC (erroneously sued and served as CF United, LLC) 2 DEFENDANTS OPPOSITION TO PLAINTIFFS® MOTION IN LIMINE NO. 2 TO EXCLUDE AND/OR PRECLUDE ANY MENTION OF OR REFERENCE TO PLAINTIFF ROSARIO MIRANDA’S MEDICAL TREATMENT BEING ON A LIEN BASIS OR ATTORNEY-REFERRED OW 0 I OO wn HB W N N N N N N N N N ND Em e m e e e m p m h E pe pe ee 0 0 1 O N Wn RA W N = D 0 N N N n n R W N D = O MEMORANDUM OF POINTS AND AUTHORITIES L INTRODUCTION On February 25, 2015, Plaintiff Rosario Miranda (“Miranda”) was using pump number 2 at a 76 gas station in Torrance when the nozzle dislodged from the hose, spilling gasoline on the ground. After the Spill, Miranda made her way into the Station’s convenience store and informed the attendant, Rosa Martinez (“Martinez”), of the spilled fuel. Martinez was not aware of the gas spill until informed by Miranda. Martinez promptly used the emergency shut off switch to stop gas flow pump number 2. Plaintiffs are not seeking to exclude evidence in this instant Motion in Limine (“MIL”) No. 2. Rather, Plaintiffs are seeking an Order forbidding a question from being asked. Plaintiffs cite no points and authorities in support of the actual request of the motion. If a question is asked that counsel objects to, an objection is raised and the court rules on it. If the objection is sustained, the jury is required to follow CACI 106 and disregard the question, noted here in pertinent part: “If I sustain an objection, you must ignore the question.” The interdependent lien relationship between Ms. Miranda’s counsel, Ms. Miranda, and Ms. Miranda’s doctors is relevant to establishing the bias of Ms. Miranda’s doctors in writing their reports, preparing their bills for services provided (including purported reasonable value of services provided), and in testifying at trial. The directive by Plaintiffs’ counsel for Ms. Miranda to see a specific doctor is compelling evidence and is probative to that bias and outweighs the low confidentiality level of the related directive. Moreover, such a relationship establishes a direct financial stake in the action by Ms. Miranda’s lien-based providers, who have worked for/been referred prior patients by Plaintiffs’ counsel. Plaintiffs attempt to conflate an attorney referral to a doctor with the attorney-client privilege, i.e., that an attorney referral was made somehow implicates the attorney-client privilege. This is inaccurate and is too broad an interpretation of the privilege. Any communication among attorney, client and doctor may be protected, but the fact that the referral was made is not privileged information. Thus, it is fair game for mention and inquiry at trial. If Plaintiffs object to this appropriate and probative line of questioning, they can object as they deem appropriate. 3 DEFENDANT’S OPPOSITION TO PLAINTIFFS® MOTION IN LIMINE NO. 2 TO EXCLUDE AND/OR PRECLUDE ANY MENTION OF OR REFERENCE TO PLAINTIFF ROSARIO MIRANDA’S MEDICAL TREATMENT BEING ON A LIEN BASIS OR ATTORNEY-REFERRED O© 00 9 a Wn ob s W N N O N N N N N N N N e m e m pe d e R E e pe e d 0 I O N WL RA W N E R E D O N Y N e W ND = O IL. PLAINTIFE’S MOTION IS PREMATURE AND IMPROPER, AS THE MOTION LACKS ARGUMENT AND FACTUAL SUPPORT Motions in limine may be inappropriate where it is difficult to specify exactly what evidence is the subject of the motion. (People v. Morris (1991) 53 Cal.3d 152, 188-190 (overruled on other grounds).) "Until the evidence is actually offered, and the court is aware of its relevance or context, its probative value, and its potential for prejudice, matters related to the state of the evidence at the time the objection is made, the court cannot intelligently rule on its admissibility." (People v. Jennings (1988) 46 Cal.3d 963, 975, n.3.) Actual testimony often defies pretrial predictions of what a witness will say on the stand. (Morris, supra, 53 Cal.3d at 188.) Events in the trial may change the context in which the evidence is offered to an extent that a renewed objection is necessary to satisfy the language and purpose of Evidence Code, §353. (Kelly v. New West Federal Savings (1996) 49 Cal. App.4™ 659, 671.) Motions in limine lacking factual support and argument are improper. Without more factual support, both Defendant and the Court are left to guess at Plaintiffs’ intentions. If allowed, such motions would force the court to "rule in a vacuum." (/d at 670.) For example, it is improper to bring a motion in limine seeking to exclude speculative testimony without any factual support or argument suggesting the nature and type of speculative testimony expected. (Id. at 671.) III. EVIDENCE AND ARGUMENT THAT MS. MIRANDA TREATED ON A LIEN BASIS IS PROPER TO ESTABLISH BIAS, INTEREST, AND/OR MOTIVE The existence of lien treatment by Ms. Miranda’s doctors is directly probative to the doctor’s bias and vested interest in the outcome of Plaintiffs’ case. Ms. Miranda is free to argue the weight of that evidence, but this MIL seeking to hide this relevant and probative evidence from the jury is really a motion to exclude evidence that hurts Plaintiffs’ case. Probative evidence is supposed to help the jury reach a fair verdict, exclusion of evidence purely because it hurts one side or another is not a basis for exclusion of that evidence. The existence of a doctor’s lien on Plaintiffs’ case is probative to the doctors’ bias in preparing their bills, attempting to establish reasonable value of services provided, and in testifying at trial. Plainly said, the more the Ms. Miranda is potentially awarded by a jury, the more the doctors can 4 DEFENDANT’S OPPOSITION TO PLAINTIFFS’ MOTION IN LIMINE NO. 2 TO EXCLUDE AND/OR PRECLUDE ANY MENTION OF OR REFERENCE TO PLAINTIFF ROSARIO MIRANDA’S MEDICAL TREATMENT BEING ON A LIEN BASIS OR ATTORNEY-REFERRED OO © 39 N n BA W N = N N N N N N N N N m E e m m R em em p m e e ed e l pe 0 NN O N nn A W N R D O Y N N N RR W N = O claim as their share, no matter how unreasonable their lien-based expenses may be. This de facto partnership should be made apparent to the jury, with the jury able to weigh the probative value of this evidence, including the weight to be afforded to Ms. Miranda’s lien-based (and financially interested) medical providers. The primary issue currently in many personal injury trials is the manner in which medical expenses and amount of expenses are presented to the trier of fact and what the parties are allowed and not allowed to introduce into evidence for the jury to consider. Competing issues are whether the plaintiff had health insurance at the time of the loss, whether the plaintiff chose to use health insurance benefits to pay for treatment, whether the plaintiff treated on a lien, and ultimately, what are the reasonable charges for the treatment, regardless of the amount billed, if not a paid amount. Tort damages consist of “the amount which will compensate for all the detriment proximately caused” by the breach at issue. (Civil Code §3333.) “Detriment is a loss or harm suffered in person or property.” (Civil Code §3282.) “Damages must, in all cases, be reasonable...” (Civil Code §3359.) Court have struggled with the issue in order to clarify the competing evidentiary problems of collateral source, medical liens, medical finance company payments and then ultimately, reasonable and customary charges. As stated in Bermudez v. Ciolek (2015) 237 Cal. App.4th 1311: But as a consequence of the discrepancy in recent decades between the amount patients are typically billed by health care providers and the lower amounts usually paid in satisfaction of the charges (whether by a health insurer or otherwise), controversy has arisen as to how to measure the reasonable costs of medical care in a variety of factual scenarios. Citing the collateral source rule, some plaintiffs suggested they should be entitled to recover the reasonable costs of medical care, even if that dollar value exceeded the amount actually paid in exchange for the medical services. But the Supreme Court rejected this approach in Howell v. Hamilton Meats (2011) 54 Cal.4th 541. “|A]n injured plaintiff whose medical expenses are paid through private insurance may recover as economic damages no more than the amounts paid by the plaintiff or his or her insurer for the medical services received or still owing at the time of trial.” In Corenbaum v. Lampkin (2013) 215 Cal. App.4th 1308, 1328-29, the court stated: “Damages for past medical 5 DEFENDANT’S OPPOSITION TO PLAINTIFFS’ MOTION IN LIMINE NO. 2 TO EXCLUDE AND/OR PRECLUDE ANY MENTION OF OR REFERENCE TO PLAINTIFF ROSARIO MIRANDA’S MEDICAL TREATMENT BEING ON A LIEN BASIS OR ATTORNEY-REFERRED OO 0 3 Oo WL» BH WwW N e N N N O N N N N N N e m e k e m e m e d e d E e e 0 J O O Wn RA W N = O D O N N Y R W N D = O expenses are limited to the lesser of (1) the amount paid or incurred for past medical expenses and (2) the reasonable value of the services.” Recently, in Pebley v. Santa Clara Organics, LLC (2018) 22 Cal.App.5th 1266, the court held that a plaintiff who treated on a lien basis who chose not use his health insurance for his injury claim, and treated “outside of plan,” was considered uninsured for purposes of determining economic damages. Thus, evidence of treatment on a lien basis was relevant to the question of what constituted reasonable and customary charges. To establish support for this evidence, plaintiff should employ expert testimony according to Pebley: When a plaintiff is not covered by health insurance, medical bills are relevant and admissible to prove both the amount incurred and the reasonable value of medical services provided, but the uninsured plaintiff also must present additional evidence, generally in the form of expert opinion testimony, to establish that the amount billed is a reasonable value for the service rendered. (Id. at 1275.) What emerges from this holding is that plaintiff and defendant will in most cases present expert testimony on the issue of reasonable and customary charges. If an injured plaintiff who is not covered by health insurance has an expert who can competently testify that the amount incurred and billed is the reasonable value of the medical service rendered, he or she should be permitted to introduce that testimony; the defendant may then test the expert’s opinion through cross-examination and present his or her own expert opinion testimony that the reasonable value of the service is lower. (Id. at 1275-1276.) As an overarching conclusion, the Pebley court stated: “A tortfeasor cannot force a plaintiff to use his or her insurance to obtain medical treatment for injuries caused by the tortfeasor, for purposes of establishing damages; that choice belongs to the plaintiff.” (/d., at 1277.) Plaintiffs argue the Pebley case stands for the proposition that evidence of treatment on a lien is irrelevant because a plaintiff who opts not to use available health insurance for accident- related treatment is considered uninsured. Although, the dust has not completely settled with the Pebley case. The holding does not necessarily translate that any mention of lien-based billing is completely inadmissible. The main thrust of the decision as a practical matter is that the parties 6 DEFENDANT’S OPPOSITION TO PLAINTIFFS® MOTION IN LIMINE NO. 2 TO EXCLUDE AND/OR PRECLUDE ANY MENTION OF OR REFERENCE TO PLAINTIFF ROSARIO MIRANDA’S MEDICAL TREATMENT BEING ON A LIEN BASIS OR ATTORNEY-REFERRED OO 0 NN O N Wn BRA W N N O N N N N O N O N N D mm e k kd em he m p m e e pe d ed 0 N N O N Wn BAA W N R O O N Y R W N = Oo will use experts to provide opinions on what is the reasonable and customary amount for the services rendered. In light of the parties’ dueling experts, the mere fact that the health care providers accepted a lien on plaintiff’s personal injury case will not be so prejudicial as to outweigh its probative value. Plaintiffs maintain that such evidence will cause the jury to speculate and thus get off track on determining the causation and damages issues. Really, the medical treatment issue boils down to testimony and on reasonable and customary. For the jury to arrive at its determination on past medical expenses, it will be presented with Plaintiffs’ version (usually “retail” charges), and Defendant’s version, according to the parties’ respective expert’s opinions. The fact that Ms. Miranda’s treatment was set up on a lien basis whereby the health care providers agreed to delay payment until the case resolves materially affects how the services are billed — this is common knowledge in the personal injury litigation legal community. Thus, there is a necessary correlation between the lien agreement and the amount of the bill; typically much higher if on a lien. This evidence is relevant and probative to the jury’s damages determination. Under the circumstances of this backdrop, evidence of treatment on a lien is relevant and admissible. It is for the trier of fact to decide the mitigation of damages question. IV. EVIDENCE AND ARGUMENT THAT MS. MIRANDA WAS REFERRED TO DOCTORS BY AN ATTORNEY IS PROPER EVIDENCE TO DETERMINE THE CREDIBILITY OF THE WITNESS BY ESTABLISHING THE EXISTENCE OF BIAS, INTEREST, OR MOTIVE OF PLAINTIFF FOR SEEKING OUT THE TREATMENT Defendant is entitled to offer evidence of a witness’ credibility, pursuant to California Evidence Code §780: Except as otherwise provided by statute, the court or jury may consider in determining the credibility of a witness any matter that has any tendency in reason to prove or disprove the truthfulness of his testimony at the hearing, including but not limited to any of the following: (f) The existence or nonexistence of a bias, interest, or other motive. 7 DEFENDANTS OPPOSITION TO PLAINTIFFS’ MOTION IN LIMINE NO. 2 TO EXCLUDE AND/OR PRECLUDE ANY MENTION OF OR REFERENCE TO PLAINTIFF ROSARIO MIRANDA’S MEDICAL TREATMENT BEING ON A LIEN BASIS OR ATTORNEY-REFERRED OO 0 NN ON Y wn BA W N 10 11 12 13 14 15 16 17 19 20 21 22 23 24 25 26 27 28 18 In the present case, evidence that Ms. Miranda sought treatment from doctors she was referred to from an attorney goes specifically to “the existence or nonexistence of a bias, interest, or other motive,” of why Ms. Miranda is seeking the medical treatment from that specific doctor beyond simply being injured. Specifically, the Court in Garfield v. Russell, found that “[e]vidence that a plaintiff is being wholly or partially compensated for her medical expenses... may be relevant on her motives in seeking medical help and her credibility as a witness, even if only remotely.” (251 Cal.App.2d 275.) While this is an extreme example of plaintiff actually receiving compensation for visiting a certain medical provider, the logic behind the ruling makes evidence of why a plaintiff would seek services from a specific doctor relevant to the plaintiff/witness’ credibility. Plaintiffs in the present case points toEvidemce Code §787 that “evidence of specific instances of conduct relevant only as tending to prove a trait of his character is inadmissible to 29 attack or support the credibility of a witness.” However, this completely and totally misses the mark and the purpose of that statute in conformity of Evidence Code §780. Specifically, Plaintiffs are attempting to paint evidence that Ms. Miranda was referred to doctors by an attorney as some kind of character evidence. Plaintiffs do not ever say what type of character evidence this would be offered or what it would be used for. Plaintiffs repeatedly confuses the issue and attempts to mislead this Court by mixing three different statutes—Section 780, Section 786, and Section 350—while attempting to exclude mention of the referrals under the guise of character evidence. While it is true that if Defendant does bring this up at trial—which of course Defendant is not confirming or denying that they will do this at trial—it would be proper under Section 780 to attack Ms. Miranda’s credibility as a witness by questioning her regarding her referral by an attorney to her treating doctors. Such evidence would establish bias, interest or motive to her claims for damages above and beyond merely pain relief. Therefore, any evidence or argument that Ms. Miranda was referred to doctors by an attorney is admissible to prove bias, interest and motive of the witness and should not be excluded as improper character evidence. 11 8 DEFENDANT’S OPPOSITION TO PLAINTIFFS” MOTION IN LIMINE NO. 2 TO EXCLUDE AND/OR PRECLUDE ANY MENTION OF OR REFERENCE TO PLAINTIFF ROSARIO MIRANDA’S MEDICAL TREATMENT BEING ON A LIEN BASIS OR ATTORNEY-REFERRED O© 0 JI O N Wn Bs W N N O D O N NN N N N N N m e m E m mm e m e e e d e d 0 ~~ O N Wn BRA W N D = O C N N N R W N = Oo V. EVIDENCE _THAT MS. MIRANDA WAS REFERRED TO DOCTORS BY AN ATTORNEY IS RELEVANT AND MORE PROBATIVE THAN PREJUDICIAL TO PLAINTIFE’S CREDIBILITY AND DOES NOT VIOLATE ATTORNEY CLIENT PRIVILEGE Plaintiffs also assert the argument that the evidence is not relevant under California Evidence Code section 350 and even if it were relevant, the probative value of the evidence is outweighed by the prejudicial effect of that evidence pursuant to Section 352. First, as demonstrated supra, evidence and argument that Ms. Miranda was referred to her treating doctors by an attorney is relevant pursuant to section 780 as it has a tendency to prove or disprove the credibility of Ms. Miranda as a witness. Further, the credibility at issue is whether Ms. Miranda has a motive beyond pain relief for seeking treatment from doctors recommended by an attorney. Second, and more importantly, the probative value of that evidence as demonstrated supra is not outweighed by the prejudicial effect or waste court resources. This is probative evidence and is relevant to her credibility. Ms. Miranda should be required to explain why she was forced to seek out doctors referred to her by an attorney. Further, Plaintiffs make a thin argument that this is attorney-client privilege. Plaintiffs cite Evidence Code section 915(a) for the proposition that attorney-client discussions concerning a referral to a doctor are privileged and not admissible at trial. Defendant has no issue with that aspect of the referral. However, the mere fact that the Ms. Miranda was or may have been referred is clearly outside of the privilege because it does not involve communication. Attorney referrals to certain doctors or other health care providers regularly occur in the normal course of handling a personal injury case. It is no different than if a friend or co-worker referred the plaintiff to a doctor in terms of admissibility at trial. The attorney-client privilege does not apply to bar mention of a doctor referral. Plaintiffs are certainly free to explore the issue with potential jurors during voir dire to eliminate, or at least take into account, that a potential juror may have an opinion about an attorney referral that may affect his/her impartiality. In fact, Plaintiffs likely will take pains to point out that Defendant’s physician billing expert is a “hired gun” for the defense. How the parties’ experts or health care professionals are mentioned certainly is a two-way street. Juries are 9 DEFENDANT’S OPPOSITION TO PLAINTIFFS’ MOTION IN LIMINE NO. 2 TO EXCLUDE AND/OR PRECLUDE ANY MENTION OF OR REFERENCE TO PLAINTIFF ROSARIO MIRANDA’S MEDICAL TREATMENT BEING ON A LIEN BASIS OR ATTORNEY-REFERRED OO 0 JI a Wn BK WwW NN N N N N N N N N N D = m em e m e m e e e e e e c o I O N Wn BA W N PR © V V 0 N N N R A W ND = Oo aware these types of referrals are regularly made in the normal course of business. There is certainly little chance such a fact will create prejudice or confusion, or waste time. VI. CONCLUSION Based on the foregoing, Defendant respectfully requests that this Court deny Plaintiffs’ Motion in Limine No. 2. Dated: March 12, 2019 COLMAN LAW GRO BY JAMES. PERKINS— BRAD A. BYSZEWSKI Attorneys for Defendant APRO, LLC (erroneously sued and served as CF United, LLC) 10 DEFENDANT’S OPPOSITION TO PLAINTIFFS’ MOTION IN LIMINE NO. 2 TO EXCLUDE AND/OR PRECLUDE ANY MENTION OF OR REFERENCE TO PLAINTIFF ROSARIO MIRANDA’S MEDICAL TREATMENT BEING ON A LIEN BASIS OR ATTORNEY-REFERRED © 0 JI O N wn Bs W N N O N N N N N N N HE E E e s e e E e e s 0 JI O O Wn BA W N = VV N N N N R W = O Re: Miranda v. APRO LLC dba United Oil Case No.: BC651713 PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I am employed in the County of Los Angeles, State of California; I am over the age of eighteen years and am not a party to this action; my business address is Colman Law Group, 500 North Brand Boulevard, Suite 2200, Glendale, California 91203, in said County and State. On March 12, 2019, I served the foregoing document described as: DEFENDANT’S OPPOSITION TO PLAINTIFFS’ MOTION IN LIMINE NO. 2 TO EXCLUDE AND/OR PRECLUDE ANY MENTION OF OR REFERENCE TO PLAINTIFF ROSARIO MIRANDA’S MEDICAL TREATMENT BEING ON A LIEN BASIS OR ATTORNEY-REFERRED on the interested parties in this action as follows: PLEASE SEE ATTACHED SERVICE LIST [VV BY MAIL (C.C.P. §§ 1013(a)): By placing the document listed above in a sealed envelope addressed to the parties set forth on the attached Service List. I am “readily familiar” with the firm’s practice of collection and processing correspondence for mailing. Under that practice it would be deposited with the United States Postal Service on that same day with postage thereon fully prepaid at Glendale, California, in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. // BY FAX TRANSMISSION (C.C.P. § 1013(e); C.R.C. 2.306: The document listed above was transmitted from fax number (818) 546-8787 to a fax machine maintained by the person on whom the document is served at the fax telephone number set forth on the attached Service List, on this date before 5:00 p.m., and a record of the transmission caused to be printed showing the date and time of the transmission, and that the transmission was reported as complete and without error [X/ BY EMAIL: I caused the attached documents to be served via email, pursuant to the recipient’s agreement to accept service via email, to the email addresses set forth herein. Electronic service of the documents listed above was done in accordance with California Rules of Court, Rule 2.251 and the transmission was reported as complete, without error. [X/ (STATE) I declare under penalty of perjury under the laws of the State of California that the above is true and correct. (C.C.P. § 2015.5) L/ (FEDERAL) I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made. Executed on March 12 9, at Glendale, California. Brad A. Byszewski J oe 11 DEFENDANT’S OPPOSITION TO PLAINTIFFS® MOTION IN LIMINE NO. 2 TO EXCLUDE AND/OR PRECLUDE ANY MENTION OF OR REFERENCE TO PLAINTIFF ROSARIO MIRANDA’S MEDICAL TREATMENT BEING ON A LIEN BASIS OR ATTORNEY-REFERRED © 0 NIN O&O wn BH WwW NN = N O N O N ND N N N N N m p d p m e m e m e m oO NN O N wn BRA W I N D = O 0 N N S Y R A W = O SERVICE LIST Re: Miranda v. APRO LLC dba United Oil Case No.: BC651713 Andrew C. Bryman andrewbryman(@gmail.com Brenden M. Norton bnorton000@gmail.com Law Offices of Bryman & Apelian 24025 Park Sorrento, Suite 220 Calabasas, CA 91302 (818)225-5151 Phone (818)225-5155 Fax Attorney for Plaintiff 12 DEFENDANT’S OPPOSITION TO PLAINTIFFS’ MOTION IN LIMINE NO. 2 TO EXCLUDE AND/OR PRECLUDE ANY MENTION OF OR REFERENCE TO PLAINTIFF ROSARIO MIRANDA’S MEDICAL TREATMENT BEING ON A LIEN BASIS OR ATTORNEY-REFERRED
