Judge: Laura A. Seigle, Case: 21STCV22952, Date: 2024-02-13 Tentative Ruling
Case Number: 21STCV22952 Hearing Date: February 13, 2024 Dept: 15
[TENTATIVE] ORDER RE MOTIONS IN LIMINE
Plaintiffs’ MIL No. 1
This motion seeks to
exclude evidence that cosmetic talc is FDA-approved because FDA does not
regulate cosmetic talc and has not determined talc is safe. This motion is too vague. It does not identify specific documents or
expert testimony to be excluded. The
motion is denied without prejudice to objections at trial.
Plaintiffs’ MIL No. 2
Plaintiffs move to
exclude statements to the effect that everyone would have mesothelioma if
cosmetic talcum powder caused the disease.
This motion is too vague. In
addition, pursuant to the July 8, 2022 CMO, motions to exclude evidence and
arguments about causation are deemed made and denied. Plaintiffs did not show good cause to depart
from that order. The motion is denied
without prejudice to objections at trial.
Plaintiffs’ MIL No. 3
Plaintiffs seek to
exclude evidence that other witnesses and attorneys used talcum powder as
irrelevant and confusing. This motion is
too vague. The court cannot predict how
this issue could arise at trial. The
motion is denied without prejudice to an objection at trial.
Plaintiffs’ MIL No. 4
Plaintiffs
seek to preclude Johnson & Johnson from referring to the “good people” at
Johnson & Johnson as prejudicial. If
Plaintiffs are seeking to exclude the term “good people,” that is a common
phrase and not inherently prejudicial.
Otherwise, the motion is too vague.
The
motion also seeks to preclude attacks against Plaintiffs’ counsel. This motion is deemed made and granted
pursuant to the July 8, 2022 CMO.
The
motion is granted in part and denied in part without prejudice to objections at
trial.
Plaintiffs’ MIL No. 5
Plaintiff moves to
exclude evidence that other defendants were sued but are not at trial and the
contents of the complaint as irrelevant and prejudicial. Defendants state they do not oppose. Therefore, they are to agree to a
stipulation.
Plaintiffs’ MIL No. 6
Plaintiffs
move to exclude evidence that Plaintiff Rochelle Krich’s family members, in
particular her father, smoked as irrelevant and prejudicial. Second-hand smoke could be relevant to
Plaintiff’s life expectancy, if an expert establishes that. The motion is denied without prejudice to
objections at trial.
Plaintiffs’ MIL No. 7
Plaintiffs move to
exclude references to the federal litigation Bell v. American International
Industries, Inc. and a workers compensation claim filed by Betty Bell as
not relevant and prejudicial.
The findings and
conclusions in the Bell v. American International Industries decision
are not admissible because the unpublished federal district court’s decision
has no preclusive effect in California state court. Likewise, the workers compensation decision
has no preclusive effect here. Allowing
evidence of those decisions will likely confuse the jury and lead them to
believe those decisions have conclusively established the issues. Also, the parties would spend time explaining
the background of the federal district court case and workers compensation decision,
Bell’s claims in those proceedings, and differences and similarities of those
proceedings with this case. This would
consume an undue amount of time in an already overly long trial.
However, the MIL seeks to
exclude all evidence about the Bell case and the workers compensation
claim, not just the final decisions in those matters. That is too broad and vague. For example there may be a deposition from
the Bell case that a party wants to use in this case. The fact that the deposition took place in
the Bell case should not, alone, make it inadmissible.
The
motion is granted in part as to the decisions in the Bell v. American
International Industries case and workers compensation case, and otherwise
is denied without prejudice to objections at trial.
Plaintiffs’ MIL No. 8
Plaintiffs move to
exclude evidence of or reference to court orders in other cases about
Plaintiffs’ experts. Court orders in
other cases are more prejudicial than probative and will consume an undue
amount of time explaining the context of those orders. Also, court orders from other cases could
reveal that defendants in this case have been sued in asbestos cases in the
past, which is prejudicial. Therefore,
the motion is granted as to court orders from other cases. However, if an expert testifies that his or
her opinions have never been excluded, limited or criticized, testifies his or
her opinions have always been accepted, or otherwise opens the door, the
evidence may be admissible, especially for impeachment. The motion is granted in part and denied in
part subject to objections at trial.
Plaintiffs’ MIL No. 9
Plaintiffs seek to
exclude evidence of a procedure called talc pleurodesis as not relevant to
causation and irrelevant, prejudicial, and confusing to the jury. If Plaintiff had this procedure, the motion
is denied without prejudice to an objection at trial. If Plaintiff did not have this procedure, the
motion is granted as the evidence would require an undue amount of trial time
and confusing medical evidence explaining the purposes of the procedure and
when and how it is used.
Plaintiffs’ MIL No. 10
Plaintiff moves to
exclude evidence about Johnson & Johnson’s complaints against Jaqueline
Moline, Theresa Emory, Richard Kradin, and John Maddox filed as part of the
Johnson & Johnson bankruptcy, in which Johnson & Johnson alleged they
had disparaged and made false statements about Johnson & Johnson’s
products. Because the federal court
dismissed the bankruptcy case, there was no ruling on those complaints.
The
fact that Johnson & Johnson filed the complaints and alleged Moline, Emory,
Kradin and Maddoxi made false and disparaging statements has no relevance. Anyone can file a lawsuit claiming someone
committed fraud, and the fact of the filing does not mean the fraud claims have
any merit. Allowing evidence that
Johnson & Johnson filed the complaints will turn this trial into a trial of
Johnson & Johnson’s fraud claims – Defendants will try to prove the Johnson
& Johnson fraud claims were true, and Plaintiffs will try to prove they
were false. This will take an undue
amount of time and will confuse the jury about what is really at issue in this
case.
While
Defendants can cross-examine Moline (assuming she is a witness) and any expert
that relies on her articles about the bases for her statements in the articles,
the motion is granted as to the Johnson & Johnson complaints filed in the
bankruptcy case.
Plaintiffs’ MIL No. 11
Defendants
filed a non-opposition to this motion, but Plaintiffs did not file this motion.
Defendants’ MIL No. 1
Defendants
move to exclude evidence about diseases caused by talc other than mesothelioma,
such as ovarian cancer. This case is not
about ovarian cancer or diseases other than mesothelioma. The evidence, especially about ovarian
cancer, would be more prejudicial than probative, would confuse the jury, and
would consume an undue amount of time in a trial that is already too long. The motion is granted.
Defendants’ MIL No. 2
Johnson & Johnson and
LTL Management move to exclude references to other lawsuits involving J&J
companies. This motion is too
vague. For example, if Defendants
dispute that they had knowledge about the hazards of asbestos, claims about
injury from asbestos could be relevant to knowledge. Therefore some references to prior cases may
be relevant. However, detailed evidence
about the prior claims and cases will be more prejudicial than probative,
confusing, and a waste of time. It will
be up to the trial court to decide how much is too much.
To the extent the motion
seeks to exclude settlements, judgments and verdicts from other litigations,
the motion is deemed made and granted pursuant to the July 8, 2022 CMO. Plaintiffs did not show good cause to depart
from that order.
Therefore,
the motion is granted in part and denied in part without prejudice to
objections at trial.
Defendants’ MIL No. 3
Defendants Johnson &
Johnson and LTL Management move to exclude evidence that they discontinued
sales of talc-based baby powder in 2020 as irrelevant, unduly prejudicial, and
confusing. If Defendants dispute that
the baby powder products contained asbestos, the discontinuation of the sales
could be relevant to proving that defect.
The motion is denied without prejudice to objections at trial.
Defendants’ MIL No. 4
Defendants
seek to exclude all media reports about talc litigation including three Reuters
articles dated December 14, 2018, April 9, 2019, and December 3, 2019, as
lacking foundation, hearsay, irrelevant and prejudicial.
The
motion to exclude all media reports is too vague.
Defendants
argue the December 14, 2018 article is hearsay, misleading and
prejudicial. Plaintiffs argue it is an
authorized statement by Defendant and is therefore admissible under Evidence
Code sections 1220 and 1222. There are
at least two problems with this argument.
First, the vast majority of the 14-page article does not contain
quotations attributed to Defendant’s authorized personnel. Second, the statements by the reporter who
wrote the article that a representative of Defendant made a particular comment
are hearsay. So even if the Defendant
made authorized admissions to the reporter, the reporter’s statements in the
article about those admissions are hearsay.
In other words, there are two levels of hearsay involved.
The article is also
prejudicial because it contains personal stories about third parties getting
sick, allegedly from Defendant’s products, as well as details about other
litigations, including cases about ovarian cancer. Details about third parties’ injuries and
their allegations about Defendant are not relevant here. The article will be confusing to the jury and
consume an undue amount of time as Defendant seeks to refute all 14 pages of it
at trial.
The article contains information
based on out-of-court sources that are themselves hearsay. In other words, it contains multiple levels
of hearsay.
Plaintiffs argues the
article is evidence that Defendant had notice of the hazards of its talcum
powder products. The article reports on
several lawsuits against Defendant concerning its talcum powder. Defendant had notice of these lawsuits well
before the article was published, for example by being served with the lawsuits
and participating in the lawsuits. If
the fact that Defendant was previously sued about its talcum powder is relevant
and not prejudicial, there are much less prejudicial ways to establish that
than via the article.
Plaintiffs
argue the December 14, 2018 article is admissible because Defendant used other
media reports in other cases as evidence.
That is irrelevant to whether the December 14, 2018 article is
admissible in this case. Simply because
different evidence was admitted in other cases does not mean this particular
article should be admitted here.
Defendant
argues the April 9, 2019 and December 3, 2019 articles are hearsay, misleading,
and prejudicial. The April 9, 2019
article discusses Defendant’s marketing campaigns, numerous ovarian cancer and
mesothelioma lawsuits against Defendant, and the events in other lawsuits
against the company. These topics are
irrelevant in this litigation, would be unduly prejudicial, and would consume
too much trial time. The December 3,
2019 article discusses an FDA symposium of asbestos in talc. Plaintiffs did not show why this article is
relevant. Also, both articles are
hearsay, and Plaintiffs did not show an exception to the hearsay rule.
The
motion is granted as to the three Reuters articles and otherwise denied without
prejudice to objections at trial.
The
moving party is to give notice.
Defendants’ MIL No. 5
Defendants Johnson &
Johnson and LTL Management move to exclude all references to IWGACP formed in
2018 and its 2020-2022 recommendations and papers as irrelevant, misleading,
and hearsay. If an expert establishes
that this is the type of background information relied upon by experts, the
evidence may be relevant and admissible even if hearsay. Defendants can then cross-examine the expert
on the fact that the work is only preliminary.
The motion is denied without prejudice to objections at trial.
Defendants’ MIL No. 6
Defendants move to
exclude evidence about foreign governmental investigations and proceedings into
talcum powder as irrelevant, prejudicial, confusing and time-consuming. Plaintiffs did not show that any defendant
was aware of a foreign investigation or proceeding into talcum powder such that
this information is relevant to notice, or that the foreign investigation or
proceeding gave the defendant notice of something it was not previously aware
of. Allowing that evidence will consume
an undue amount of trial time exploring the reasons for the foreign
investigations. The evidence would have
little probative value because foreign investigations do not result in
regulations or law in the United States and would be confusing to the jury. The motion is granted.
Defendants’ MIL No. 7
Johnson
& Johnson and LTL Management move to exclude statements that litigation
forced Defendants to make public the story of asbestos in cosmetic talc. Plaintiffs state they need to discuss other
litigations against Defendants to show that Defendants have been concealing the
truth.
Except
as discussed above, evidence of other lawsuits against Defendants regarding
talc will be time consuming and prejudicial.
It will result in spending time at trial about how and why Defendants
acted the way it did in the other lawsuits.
This will waste time and result in a re-litigation of the previous
lawsuits. Plaintiffs can present
evidence of concealment without delving into the other lawsuits. The motion is granted.
Defendants’ MIL No. 8
Johnson
& Johnson and LTL Management move to exclude an article titled “Asbestos in
Commercial Talcum Powder as a Cause of Mesothelioma in Women” by Gordon,
Millette, and Fitzgerald as hearsay, based on improper data, and unreliable.
An expert may rely on
hearsay and tell the jury in general terms that he or she did so. If an expert testifying in this case
establishes that this article is the type of background information relied upon
by experts in the field, the evidence may be relevant and admissible even if
hearsay. (People v. Veamatahau
(2020) 9 Cal.5th 16, 22.) Defendants did
not show that the article is based on data lacking foundation or an unreliable
method. Defendants can cross-examine any
expert who relies on this article about these points.
The
motion is granted in part as to the contents of the article unless an expert
establishes a basis for its admissibility.
Otherwise the motion denied without prejudice to objections at trial.
Defendants’ MIL No. 9
Johnson & Johnson and
LTL Management seek to exclude an article written by Dr. Jacqueline
Moline.
The articles is hearsay,
but an expert can rely on hearsay and tell the jury generally that he or she
relied on the hearsay. The expert cannot
tell the jury the contents of the hearsay unless the expert first establishes
that the paper is the type of general background information relied upon by
experts in the field or the document is otherwise admissible. That Moline wrote the article as part of
litigation goes to the author’s potential bias and the weight for the jury to
give to the article.
Defendants
argue the article is unreliable, ignores other cases, and is selective about
the information it uses. If some expert
in this case testifies that he or she relied on the article, Defendants can
cross-examine the expert about the other cases the article ignores. This issue goes to the weight to be given the
article and opinions based on the article.
That the article supposedly relied on false information is also grounds
for cross-examination.
Defendants
argue no expert can reasonably rely on the article. That cannot be determined until the expert
testifies and explains why the expert believes the article is reliable.
Defendants
argue Moline refuses to answer questions about her article. However, Defendants did not show they
subpoenaed Moline for a deposition and she refused to answer questions in this
case. If she is a witness in this trial
and refuses to answer questions at trial, Defendants can seek object or seek to
have her testimony stricken at that time.
The
motion is granted in part as to the specific contents of the article unless an
expert establishes a basis for the admissibility of the contents at trial. Otherwise the motion is denied without
prejudice to objections at trial.
The
moving party is to give notice.
Defendants’ MIL No. 10
Johnson
& Johnson and LTL Management move to exclude all references to a paper
authored by Teresa Emory, John Maddox, and Richard Kradin. The paper is hearsay, but an expert can rely
on hearsay and tell the jury generally about the hearsay. The expert cannot tell the jury the contents
of the hearsay unless the expert first establishes that the paper is the type
of general background information relied upon by experts in the field or is
otherwise admissible.
Defendants
argue the paper should be excluded because the authors regularly testify for
plaintiffs in talc cases. That may be a
basis to argue to the jury that they should view the article with suspicion and
give it no weight, but it is not a legal ground for excluding expert testimony
(if that were the law, many experts in asbestos cases would automatically be
excluded).
Defendants
argue that the paper does not disclose the source of its data and the authors
refuse to turn over their data. However,
Plaintiffs do not state that they sought the data in discovery in this case.
Defendants
argue the paper contains false, one-sided, cherry-picked data. That is grounds for cross-examination and
goes to the weight the jury should give the article.
The
motion is granted in part as to the specific contents of the paper unless an
expert establishes a basis for the admissibility of the contents. Otherwise the motion denied without prejudice
to objections at trial.
Defendants’ MIL No. 11
Johnson
& Johnson and LTL Management move to exclude evidence that Alice Blount
tested Defendants’ talc and found asbestos because she is not an expert in this
case and her conclusions are unreliable.
Written
reports and out-of-court statements by Blount about her testing of talc and the
results are hearsay if offered for the truth of the matter asserted. An expert designated and testifying in this
case cannot tell the jury the contents of that hearsay unless the expert first
establishes that the written or oral statements by Blount are the type of
general background information relied upon by experts in the field or the
statements are otherwise admissible.
However, an expert may rely on hearsay and tell the jury that he or she
relied on the hearsay.
Whether
Blount’s work is reliable such that other experts in the field generally rely
upon it as accurate must be established by a testifying expert in this case
first before Blount’s statements are potentially admissible.
Plaintiffs
argue Blount’s deposition testimony from a prior case is admissible. Prior deposition testimony is to be handled
pursuant to the procedures set forth in the July 8, 2022 CMO.
The
motion is granted in part as to written and oral statements (other than prior
deposition testimony, which is handled pursuant to the July 8, 2022 CMO) by
Blount unless an expert establishes a basis for the admissibility of those statements
at trial. Otherwise the motion is denied
without prejudice to objections at trial.
The
moving party is to give notice.
Defendants’ MIL No. 12
Defendants
move to exclude references to Plaintiff’s family members being Holocaust
victims before she was born as irrelevant and prejudicial. The Holocaust is not relevant to this case
and would be used to elicit sympathy for Plaintiff. The motion is granted.
Defendants’ MIL No. 13
This
motion in limine seeks an order that witnesses, documents and demonstratives be
disclosed. This is not a proper motion
in limine. The trial court will have its
own rules for trial procedure.
Therefore, the motion is denied without prejudice.
Defendants’ MIL No. 14
Defendants
move to exclude evidence of a conspiracy among defendants and others. Because the court granted Defendant’s
unopposed motion for summary judgment on the conspiracy cause of action, the
claims about a conspiracy are no longer part of this case. The motion is granted.
Defendants’ MIL No. 15
Johnson
& Johnson and LTL Management moves to exclude references to the LTL
Management bankruptcy proceedings. The
bankruptcy is irrelevant and will create time-consuming sideshow. The motion is granted.
The
moving party is to give notice.