Woman Suffers Multiple Injuries in Car Accident

The following blog entry is written to illustrate a common motion filed during civil litigation. Reviewing this kind of filing should help potential plaintiffs and clients better understand how parties in personal injury cases present such issues to the court.

(Please also note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this car accident lawsuit and its proceedings.)

Plaintiff Robyn Anderson’s Motion in Limine #4 to Exclude Argument or Reference to the Defense Medical Expert as Independent or to Use the Term Independent Medical Examination

Plaintiff respectfully moves the Court for Orders in Limine prohibiting attorneys for all parties from referring to the defense medical expert as independent or to use the term independent medical examination.

This motion is made on the ground that the described order is necessary to ensure that the plaintiff will be accorded a fair trial, and that the trial record in this case will not be tainted, and that the comment or reference to the defense hired expert witnesses as independent creates a substantial danger of prejudice and confusion, and would mislead the jury.

For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.

MEMORANDUM OF POINTS AND AUTHORITIES
SUMMARY
On October 17, 2008, while driving a 2002 Universal school bus, defendant Ellen White entered the intersection of Pierson Boulevard and Tulip Drive in Sacramento, in front of plaintiff, Robyn Anderson, who was traveling northbound on Tulip Drive in her 2003 Ford Taurus.

Plaintiff collided into Defendants’ vehicle and suffered serious injuries and other damages as a result of said collision. Defendants deny responsibility for any injuries or losses and dispute the nature and extent of Plaintiff’s damages.

Defendant hired Stanley Lee, M.D. and Daniel Browne, M.D., to examine plaintiff. (See Part 2 of 2.)

For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.