Almer v. Peanut Corporation of America

Filing 1985

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Almer v. Peanut Corporation of America Doc. 1985 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA THIRD DIVISION In re: Guidant Corp. Implantable Defibrillators Products Liability Litigation This Document Relates to Leopoldo Duron, Jr. vs. Case No. 06-00025 Guidant Corp., et al. DEFENDANTS' CONSOLIDATED MOTION IN LIMINE Defendants Guidant Corporation, Guidant Sales Corporation, Cardiac Pacemakers, Inc., respectfully submit this Motion in Limine to exclude the improper use of various categories of evidence during trial or in the presence of the jury: I. Evidence of Any Merger or Acquisition in Which Defendants Were Involved or Potentially Involved, or Guidant's Employees' or Independent Contractors' Compensation or Securities Transactions Statements About or References to Any Plaintiff That is Not a Named Device Recipient in This Case Statements About or References to Any Guidant Products or Recalls of Products Other Than the Ventak Prizm 2 Dr, Model 1861 Statements, Documents, Testimony or References Regarding Other Litigation or Investigations, Including by the SEC, DOJ, Attorneys General or Congress Statements About, References to, Testimony Regarding, or Documents Regarding the Ancure Endograft System or Guidant's Corporate Integrity Agreement Statements, Documents, Testimony or References to Subsequent Remedial Measures (Consolidated) Evidence of Shipment and Sale of "Pre-Mitigation" Devices After the April 2002 Manufacturing Change MDL No. 1708 (DWF/AKB) II. III. IV. V. VI. VII. VIII. References to or Evidence of Medical Complications 694686 IX. Evidence Regarding Non-Parties in Support of Punitive Damages WHEREFORE, Defendants pray that the Court grant Defendants' Motion In Limine. Respectfully submitted, SHOOK, HARDY & BACON L.L.P. By: /s/ Timothy A. Pratt Missouri Bar No. 26729 2555 Grand Blvd. Kansas City, Missouri 64108-2613 Telephone: 816.474.6550 Facsimile 816.421.5547 Joseph M. Price FAEGRE & BENSON 2200 Wells Fargo Center 90 South Seventh Street Minneapolis, MN 55402-3901 Telephone: 612.766.7000 Facsimile: 612.766.1600 Attorneys for Defendants 694686

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