Free Motion in Limine - District Court of Connecticut - Connecticut

Case 3:00-cv-00835-CFD Document 308 Filed 1 1/26/2003 Page 1 of 3 {
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INDYMAC BANK, F.S.B.
Plaintiff CIVIL ACTION NO.
. 3:00CV835 (CFD)
V. I _ R
MOSTAFA REYAD AND WAFA REYAD
Defendants
DATE: NOVEMBER 24, 2003
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DEFENDANT MOSTAFA REYAD’S SECOND MOTION IN LIMINE
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Defendant Mostafa Reyad hereby respectfully move this Court to Strike certain
inadmissible evidence out of the records of the Joint Trial Memorandum. Plaintiff’ S
contention to move all issues to Trial including inadmissible evidence is improper, and
contrary to the Rules of Court. Plaintiff consumed more than two (2) years to show his
identity complicated Defendant’s proceeding. Now, Plaintiff attempting to block
Defendant’s issues which were raised during pretrial and not ruled upon. This Court
Ruled upon and Denied the Summary judgement founded on preclusion. The Court did
not Rule on material issues raised by Defendant. Defendant’s issues emerge evidentiary
problems. Defendant attempts to solve it in the first motion in limine, Plaintiff avoids
response. Defendant hereby providing the evidence, and not asking Plaintiff to provide it.
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-· ~ Case 3:00-cv-00835-CFD Document 308 Filed 1 1/26/2003 Page 2 of 3 I i
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Defendant traveled to California and obtained certified copies of the complete certificate I
‘ of qualification for WLCA and IndyMac Mortgage Holdings, Inc. Plaintiff provided I
exhibit "J" ofthe Trial Memorandum includes 127 exhibits. This Motion in limine is to
strike four (4) exhibits out of the 127, if the Court Grant this motion, all the remaining
127 would be moot.
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As it is demonstrated in the accompanied Memorandum of Law. This motion to Strike i
Plaintiff s exhibit number 22-25; these exhibits are: l
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1. Fictitious Business Name Statement of Independent Lending Corporation, filed in I
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Los Angeles County, California, dated 10/13/94, exhibit # 22 »
2. Fictitious Business Name Statement of IndyMac Mortgage Holdings, Inc. filed in Los
Angeles County, California, dated 8/21/98, exhibit # 23
3. Registration of Trade names form of IndyMac Mortgage Holdings, Inc. filed in New
Castle County, Delaware, dated 8/12/98, exhibit # 24 i
4. Trade name certificate of IndyMac Mortgage Holdings, Inc. filed in Hanford,
Connecticut, dated 8/24/98, exhibit # 25
The above four (4) documents are improperly filed and should be stricken out ofthe
records of Joint Trial Memorandum.
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·' ‘* Case 3:00-cv-00835-CFD Document 308 Filed 11/26/2003 Page 3 of 3 1
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The Defendant
Most a Reyad
By: ·· .
Mostafa Reyad
2077 Center Ave # 22D
Fort Lee, NJ 07024
Day Phone # 203—325-4100 ‘
Home Phone # 201-585-0562 ·
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CERTIFICATION 4
The Undersigned certifies that he mailed a true and correct copy of this Motion to
D Attorney David Schaefer 271 Whitney Avenue, New Haven, CT 06511 and Wafa Reyad
at 2077 Center Avenue # 22D, Fort Lee, NJ 07024. _
Mostafa Rgyad I
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