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1 Lawrence A. Organ, Esq.

(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
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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 I. INTRODUCTION
2 Defendants move to exclude any reference to the name of the one of the firms
3 representing Plaintiff. Defendants do so without citation to any authority apart from a general
4 reference to Evidence Code section 352. Defendants’ motion, containing neither argument nor
5 citations, should be denied.
6 II. “CALIFORNIA CIVIL RIGHTS LAW GROUP” IS NOT PREJUDICIAL
7 Evidence Code section 352 does not apply to the name of a party’s representative. It
8 applies only to evidence. A law firm name is not evidence. Defendants’ motion should be denied
9 on this ground alone. Defendants’ motion should also be denied as untimely. 1 Regardless,
10 Plaintiff’s counsel is not “trying to project themselves as a government civil rights unit,” and the
11 use of counsel’s firm name and logo would not be unduly prejudicial.
12 First, as to the name of Plaintiff’s attorneys’ firm, Defendants claim: “The name . . .
13 suggest that Plaintiff is being represented by a California state agency.” That is the entirety of
14 Defendants analysis on this point. A review of the words comprising “California Civil Rights
15 Law Group” is useful: “California” identifies the state in which Plaintiff’s counsel practices;
16 “civil rights” identifies the area of law practiced; “law group,” a term used by innumerable law
17 firms, including Defendants’ counsel, is synonymous with “X & Associates” or “Law Firm.”
18 (See, e.g., Luis E. Ventura, “X & Associates,” “Y Law Group,” “Z Law Firm”: What’s in a
19 Name Anyway?, Legal Ethics Corner, SAN DIEGO COUNTY BAR ASSOCIATION, available at
20 https://www.sdcba.org/index.cfm?pg=LegalEthicsCorner-8-2.) The firm does not identify itself
21 as an “agency,” “department,” “bureau,” or any other government body.
22 Second, Defendants claim that the firm uses a “California State government symbol as
23 part of its logo,” thereby suggesting it is a governmental entity. The firm’s logo includes the
24 grizzly bear, which is the state animal of California and appears on the state flag of California,
25 clutching the scales of justice in its mouth. Defendants’ is not a legal argument. It states no issue,
26 relevant rule, or analysis. The state of California has at least 38 official symbols, including state
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The deadline to file and serve motions in limine was on April 2, 2019, pursuant to the Court’s
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standing order. Defendants’ did not attempt to serve their motion until April 3; they did so by
email despite the fact that the parties did not have an electronic service agreement.

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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