Professional Documents
Culture Documents
(SBN 175503)
Julianne K. Stanford, Esq. (SBN 290001)
2 Noah Baron, Esq. (SBN 321960)
3 CALIFORNIA CIVIL RIGHTS LAW GROUP
332 San Anselmo Avenue
4 San Anselmo, California 94960
Tel.: (415) 453-4740
5 Fax.: (415) 785-7352
6 Email: larry@civilrightsca.com
Email: julianne@civilrightsca.com
7 Email: noah@civilrightsca.com
8 Rory Quintana, SBN 258747
9 Ramsey Hanafi, SBN 262515
QUINTANA HANAFI LLP
10 870 Market Street, Suite 1115
San Francisco, CA 94102
11 Tel: (415) 504-3121
12 Fax: (415) 233-8770
rory@qhplaw.com
13 ramsey@qhplaw.com
14 Attorneys for Plaintiff,
15 GLORIA MULDER
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IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
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IN AND FOR THE COUNTY OF ALAMEDA
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19 GLORIA MULDER, ) Case No. RG17868998
)
20 Plaintiff, ) Assigned for all purposes to Hon. Robert
) McGuiness, Dept. 22
21
v. )
22 ) PLAINTIFF’S OPPOSITION TO
CHILDREN’S HOSPITAL & RESEARCH ) DEFENDANTS’ MOTION IN LIMINE NO. 7
23 CENTER AT OAKLAND, a California ) TO EXCLUDE THE FIRM NAME
Corporation, doing business as UCSF ) “CALIFORNIA CIVIL RIGHTS LAW
24 GROUP”
BENIOFF CHILDREN’S HOSPITAL )
25 OAKLAND; GREG COYNE; and DOES 1-10, )
inclusive, ) Final Pretrial Conf: April 12, 2019
26 ) Time: 8:30 AM
Defendants. ) Dept: 22
27 Trial Date: April 22, 2019
)
_____________________________________
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PLAINTIFF’S OPPOSITION TO DEFENDANT’S MOTION IN LIMINE NO. 7
1 colors (blue and gold), a state vegetable (artichoke), a state folk dance (square dance), a state
2 fabric (denim), a state nut (almond), a state outdoor play (the Ramona Pageant), and more.
3 Surely their use by private businesses is not tantamount to portraying a company as a
4 government agency. Nobody mistakes a bottle of Anchor Brewing Company’s California Lager,
5 whose label also includes a grizzly bear, for a government-provided libation. (See Anchor
6 Brewing Company Launches Anchor California Labor and Form Partnership with California
7 State Parks Association (February 7, 2013), https://www.anchorbrewing.com/connect/news/95.)
8 Notably, the overwhelming majority of California’s 235 government agencies––including, most
9 pertinently, the Department of Fair Employment and Housing––do not include the grizzly bear in
10 their logos at all. (See Agency Search, State of California website (last visited April 7, 2019),
11 available at https://www.ca.gov/agencysearch/.) And the few that do neither have a logo
12 resembling the one here nor engage in employment litigation. Defendants’ concerns are therefore
13 misplaced.
14 Third, Defendants fail to explain why—even were a juror to think the California Civil
15 Rights Law Group is a government agency—the logo and name of the California Civil Rights
16 Law Group would be “unduly prejudicial” beyond making speculative assertions claiming that
17 juries are more likely to believe claims made by government agencies. If true, this would raise
18 significant concerns as the elimination of individuals with such biases is a crucial part of the jury
19 selection process. Yet the Defendants have offered no evidence whatever that their claims are
20 true, either generally or in this particular instance.
21 Finally, Plaintiff notes the irony of Defendants’ motion: Defendants are represented by a
22 firm called the “Renne Public Law Group” (emphasis added). Unlike “California Civil Rights
23 Law Group,” Defendants’ counsel’s firm explicitly asserts that it operates as a “public” law
24 group when, in fact, it is a private firm.
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PLAINTIFF’S OPPOSITION TO DEFENDANT’S MOTION IN LIMINE NO. 7
1 III. CONCLUSION
2 For these reasons, the Court should deny Defendants’ Motion in Limine No. 7 in its
3 entirety.
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5 Dated: April 8, 2019 CALIFORNIA CIVIL RIGHTS LAW GROUP
QUINTANA HANAFI LLP
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8 Noah Baron, Esq.
9 Attorneys for Plaintiff Gloria Mulder
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PLAINTIFF’S OPPOSITION TO DEFENDANT’S MOTION IN LIMINE NO. 7