Motion-Secondary: CYNTHIA MEYER VS FARMERS FINANCIAL SOLUTIONS LLC ET AL

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 02/24/2022 04:58 PM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Soto,Deputy Clerk


                   1            THARPE & HOWELL, LLP
                           15250 Ventura Boulevard, Ninth Floor
                   2          Sherman Oaks, California 91403
                             (818) 205-9955; (818) 205-9944 fax
                   3
                         CHRISTOPHER S. MAILE, ESQ.; STATE BAR NO.: 117998
                   4     SEAN P. DUCAR, ESQ.; STATE BAR NO.: 295541

                   5     Attorneys for Defendants, FARMERS FINANCIAL SOLUTIONS, LLC;
                         FFS HOLDING, LLC
                   6

                   7

                   8                                     SUPERIOR COURT OF THE STATE OF CALIFORNIA

                   9                                               COUNTY OF LOS ANGELES - CENTRAL

                 10

                 11      CYNTHIA MEYER,                                                              Case No. BC625867

                 12                                         Plaintiff,                               Complaint Filed: July 5, 2016
                                                                                                     Civil Unlimited Jurisdiction
                 13      v.                                                                          [Assigned to the Hon. Robert B. Broadbelt,
                                                                                                     Department 53]
                 14      FARMERS FINANCIAL SOLUTIONS,
                         LLC, FFS HOLDING, LLC, COURTNEY                                             DEFENDANTS FARMERS FINANCIAL
                 15      SAYE, JOHN MUETING, and DOES 1 to                                           SOLUTIONS, LLC AND FFS HOLDING,
                         100, inclusive,                                                             LLC’S REPLY BRIEF RE MOTION IN
                 16                                                                                  LIMINE NO. 6
                                                            Defendants.
                 17
                                                                                                     FSC Date: March 4, 2022
                 18                                                                                  Time:     11:00 a.m.
                                                                                                     Dept.:    53
                 19
                                                                                                     Trial:             March 23, 2022
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                 21                  Meyer’s opposition provides no legitimate basis for her flawed argument that evidence
                 22      surrounding her November 2014 leave of absence should be permitted at trial. First, Meyer falsely
                 23      claims that because Defendants’ motion lacks particularity about what evidence it seeks to exclude,
                 24      it should be denied pursuant to Local Rule 3.57. (Opp. at 1:9-13.) This incorrect proposition
                 25      makes no sense, as Defendants’ motion specifically identifies the evidence alleged to be
                 26      inadmissible. Defendants are attempting to prevent Meyer from introducing any evidence and/or
                 27      argument which relates to the circumstances surrounding her November 2014 leave of absence.
                 28      Meyer’s questionable assertion that she would have to “guess at the evidence actually at issue” is
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                                                             DEFENDANTS’ REPLY BRIEF RE MOTION IN LIMINE NO. 6