Opinion
CASE NO. C 11-01950 SBA
03-13-2013
CRAIG YATES, an individual; Plaintiff, v. SWEET POTATO ENTERPRISE, INC., a California Corporation dba POPEYES STORE # 2794; and KUAN L. NG and HELEN L. NG, Trustees, of THE KUAN L. NG AND HELEN L. NG REVOCABLE TRUST OF 1993, Defendants.
THOMAS E. FRANKOVICH (State Bar No. 074414) GEORGE S. KHOURY (State Bar No. 269738) THOMAS E. FRANKOVICH, A Professional Law Corporation Attorneys for Plaintiff CRAIG YATES, an individual Tyler M. Paetkau (SBN 146305) James H. Harnett (SBN 84587) Charles J. Smith (SBN 72700) HARTNETT, SMITH & PAETKAU Attorney for Defendants SWEET POTATO ENTERPRISE, INC., a California Corporation dba POPEYES STORE # 2794; and KUAN L. NG and HELEN L. NG, Trustees, of THE KUAN L. NG AND HELEN L. NG REVOCABLE TRUST OF 1993
THOMAS E. FRANKOVICH (State Bar No. 074414)
GEORGE S. KHOURY (State Bar No. 269738)
THOMAS E. FRANKOVICH,
A Professional Law Corporation
Attorneys for Plaintiff
CRAIG YATES, an individual
Tyler M. Paetkau (SBN 146305)
James H. Harnett (SBN 84587)
Charles J. Smith (SBN 72700)
HARTNETT, SMITH & PAETKAU
Attorney for Defendants
SWEET POTATO ENTERPRISE, INC.,
a California Corporation dba POPEYES STORE # 2794;
and KUAN L. NG and HELEN L. NG, Trustees,
of THE KUAN L. NG AND HELEN L. NG
REVOCABLE TRUST OF 1993
JOINT CERTFICATION OF COUNSELS'
MEET AND CONFER RE: MOTIONS IN
LIMINE AND STIPULATION TO
EXCLUDE MENTION OF, OR
EVIDENCE RELATING TO, CERTAIN
ISSUES AND ORDER THEREON
The parties to the above-captioned action, through their respective counsels, jointly submit this Certification that Counsel for plaintiff and defendants have met and conferred as to each issue raised by the Motions In Limine presented to this Court, pursuant to Judge Armstrong's September 21, 2012 Standing Order, and the February 14, 2013 Order Striking Plaintiff's Motions In Limine.
On February 15, 2013, attorney George S. Khoury, for plaintiff, and attorneys Tyler Paetkau and Olga Savage, for defendants, did meet and confer as to each and every issue raised in the respective motions in limine. Counsel discussed each issue in good faith, and attempted to resolve each issue informally.
In discussing the issues, counsel were able to agree to, and hereby stipulate that:
1.) Defendants will not mention, or seek to introduce into evidence, information that relates to plaintiff CRAIG YATES receipt of disability benefits and social security.
2.) Plaintiff will not mention, or seek to introduce into evidence, information relating to how plaintiff CRAIG YATES became disabled.
Respectfully submitted,
THOMAS E. FRANKOVICH,
A PROFESSIONAL LAW CORPORATION
By: _______________
Thomas E. Frankovich
George S. Khoury
Attorneys for Plaintiff CRAIG YATES
HARTNETT, SMITH & PAETKAU
By: _______________
Tyler Paetkau
Olga Savage
Attorneys for Defendants SWEET POTATO
ENTERPRISE, INC., a California Corporation dba
POPEYES STORE # 2794; and KUAN L. NG and
HELEN L. NG, Trustees, of THE KUAN L. NG
AND HELEN L. NG REVOCABLE TRUST OF
1993
ORDER
IT IS SO ORDERED that pursuant to the stipulation of the parties: 1.) defendants shall not mention, or seek to introduce into evidence, at trial, information that relates to plaintiff CRAIG YATES receipt of disability benefits and social security; and 2.) plaintiff shall not mention, or seek to introduce into evidence, at trial, information relating to how plaintiff CRAIG YATES became disabled.
_______________
Honorable Judge Saundra Brown Armstrong
United States District Court, Northern District
of California