![]() ![]() INTRODUCTION Defendants' Motion in Limine to Exclude Lay Witness Testimony ("Motion") seeks to exclude testimony from twelve of the fourteen fact witnesses Plaintiff Log Cabin Republicans ("Log Cabin") may introduce at trial. ![]() Deckers Outdoor Corp., 259 F.3d 1101 (9th Cir. Dep't of the Air Force, 527 F.3d 806 (9th Cir. Washington State Republican Party, 552 U.S. Goodyear Tire & Rubber Co., 529 F.2d 708 (6th Cir. 21 Planned Parenthood of Southeastern Pa. Construction Protective Services, Inc., 541 F.3d 1175 (9th Cir. County of San Luis Obispo, 548 F.3d 1184 (9th Cir. City & County of San Francisco, 196 F.R.D. TABLE OF AUTHORITIES Page(s) FEDERAL CASES Benson v. 24 A Motion in Limine Is the Improper Means for Objecting to Designated Deposition Testimony. ![]() The Designated Testimony Is Admissible.19 The Specific Areas of Inquiry Are Relevant. 18 The Testimony of the 30(b)(6) Witnesses Is Relevant and Admissible. 16 Log Cabin Is Entitled to Present Testimony of Six Out of the Thousands of Unique Individuals Discharged Under, or Impacted by, DADT. The LCR Representatives.15 Defendants' Request to Exclude All Contemplated Testimony Is Procedurally and Substantively Improper. 11 Any Delay in Disclosure of Lay Witnesses Was Substantially Justified and Harmless.12ฤก. Defendants' Compound Motion is Procedurally Improper.8 Log Cabin Properly Disclosed the Identities of Its Lay Witnesses.9 A. 2 THE COURT SHOULD DENY DEFENDANTS' MOTION. CV04-8425 VAP (Ex) PLAINTIFF LOG CABIN REPUBLICANS' OPPOSITION TO DEFENDANTS' MOTION IN LIMINE TO EXCLUDE LAY WITNESS TESTIMONY DATE: JTime: 2:30 p.m. GATES, SECRETARY OF DEFENSE, in his official capacity, Defendants. UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA LOG CABIN REPUBLICANS, a nonprofit corporation, Plaintiff, v. Fifth Street, Suite 1900 Los Angeles, CA 90071-2007 Telephone: (213) 620-7700 Facsimile: (213) 452-2329 Email: Email: Email: Attorneys for Plaintiff Log Cabin Republicans FELDMAN (SBN 246394) WHITE & CASE LLP 633 W. ![]()
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