Advanced Trial Tactics: Tips From the Experts on Motions in Limine

Jay Spillane is the founding shareholder of Spillane Trial Group PLC, a firm of business trial lawyers representing private companies and individuals in “bet-the-company” cases, where fortunes and futures are on the line. For over three decades, Spillane has tried cases for entertainment and sports personalities such as Robert Redford, Harold Ramis, surf champion Kelly Slater and beach volleyball gold medalist Kent Steffes, and for companies and high level executives in cases involving entertainment, intellectual property, technology, real estate, finance, corporate control and family wealth.

Spillane eschews a tedious style of presenting trials, in which “lawyer-speak” abounds and every small detail is referenced for fear that something might be omitted. He believes that every business trial can be boiled down to ethical principles every juror should have learned by high school: keep your promises, don’t lie, don’t copy, and treat others as you would yourself. This approach often brings forth good settlements, and when a case cannot settle, the best results at trial.

Spillane not only tries cases but handles all level of appeals. He represented Internet billing company CCBill LLC and web host CWIE LLC in the seminal case Perfect 10, Inc. v. CCBill, LLC, 340 F. Supp. 2nd 1077 (C.D. Cal. 2004), aff’d in part, 488 F.3d 1102 (9th Cir. 2007), cert. denied, 129 S. Ct. 709 (2007), one of the most-cited cases concerning when Internet service providers may be immune from, or held secondarily liable for, allegedly infringing content on client websites.

Edward J. Weiss, Esq. is a distinguished attorney with a stellar track record of legal expertise and a commitment to delivering exceptional results. With over three decades of experience as a mediator, arbitrator, trial lawyer, federal prosecutor, general counsel, and business leader, Mr. Weiss has established himself as a respected figure in the legal community.

Since 2021, Mr. Weiss has dedicated himself full-time to mediating and arbitrating disputes. He has also volunteered as a mediator for the Los Angeles Superior Court. Throughout his career, he has showcased his proficiency in various areas of law, with a primary focus on antitrust, business and commercial, class action, employment, entertainment, intellectual property, real estate, and securities matters. His comprehensive understanding of complex legal issues, combined with his strong analytical skills, has enabled him to assist a diverse range of clients, from individuals to multinational corporations, in successfully resolving their disputes.

As a litigator and trial lawyer, Mr. Weiss has extensive experience handling, resolving, litigating, managing, and trying a wide variety of civil and criminal cases in State and Federal Court on behalf of both plaintiffs and defendants, including cases in arbitration and mediation, involving consumer, commercial, and employment law issues. During his time as General Counsel, Chief Counsel, and Executive Vice President for Ticketmaster, Mr. Weiss spent a total of 18 years overseeing the company’s litigation matters, including intellectual property, commercial, antitrust, securities, employment and consumer disputes. He played a key role in developing and implementing legal strategies to protect the company’s proprietary technology from unauthorized access and successfully defended the company in a major federal antitrust case brought by a competitor.

Mr. Weiss earned his J.D. from the University of California, Berkeley, School of Law and an A.B. in Political Science from the University of California, Berkeley.

Randolph M. Hammock is a Superior Court Judge, currently sitting in an Independent Calendar (“IC”) Court at the Stanley Mosk Courthouse, in which he presides over unlimited civil cases. He graduated from San Diego State University (1980) and the University of San Diego, School of Law (1983). During his almost 25 years of practicing law (primarily as a civil trial attorney), Judge Hammock was admitted to and actively practiced law in a total of 15 states, as well as over 20 federal district courts and courts of appeal. As such, he is likely to have had passed more bar exams than any other practicing lawyer in the United States. He was a member of LATLA/CAALA from the mid 1980s to his appointment as a Superior Court Referee in the juvenile dependency court in 2008, where he served until he was elected as a Judge of the Los Angeles Superior Court in 2010. He has been a member of the American Board of Trial Advocates (ABOTA) since 2000.

Paul Kiesel received his Juris Doctorate from the Whittier College School of Law in Los Angeles in 1985. In 2005, he was awarded an Honorary Doctorate of Law from Whittier Law School. His practice is devoted to representing consumers in personal injury, class action, environmental, and toxic tort litigation.

Mr. Kiesel has repeatedly been selected as one of the top plaintiff attorneys in the State of California and the country. The Los Angeles Business Journal recognized Mr. Kiesel as one of the Top 50 Trial Lawyers. The Daily Journal named Mr. Kiesel one of the 100 most influential attorneys in the State of California. He was also selected as one of the top 500 attorneys in the United States by Law Dragon. In addition, Mr. Kiesel is rated A.V. (highest rating) by Martindale-Hubbell.

Paul Kiesel is very active in the legal community. He was the president of the Los Angeles County Bar Association for 2015-2016 and was the past Chair of the Litigation Section. He was appointed by former Chief Justice Ronald George to the State of California Judicial Council Civil and Small Claims Advisory Committee. He served on the Board of Governors for the Consumer Attorneys of California and the Consumer Attorneys Association of Los Angeles for over 25 years. In recognition of his service, Mr. Kiesel was elected an emeritus (lifetime) board member of both organizations. From 2001-2005, Mr. Kiesel sat on the Board of Governors of the Association of Business Trial Lawyers. Mr. Kiesel was the Co-Chair of the Open Courts Coalition, a bipartisan committee of attorneys from throughout California advocating full-funding of the civil justice system. Members of the Open Courts Coalition include the Honorable Carlos Moreno, former Governors Gray Davis and George Deukmejian, Los Angeles Mayor Antonio Villaragosa, and former California Attorney General John VanDekamp.  Recently, Mr. Kiesel was named a Senior Fellow of the Litigation Counsel of America, a trial lawyer honorary society composed of less than one-half of one percent of American lawyers, dedicated to promoting superior advocacy, professionalism and ethical standards in the legal profession.

Mr. Kiesel has extensive experience in complex litigation, including environmental, construction defect, product defect, and pharmaceutical actions. Mr. Kiesel served as national Lead Counsel in the federal Multi-District Litigation against Glaxo Smith Kline for injuries caused by its pharmaceutical drug, Avandia. There were over 20,000 personal injury cases, a half-dozen consumer class cases, and several state actions pending in the Avandia MDL. Mr. Kiesel served as Liaison Counsel in the litigation arising out of the 2008 Chatsworth Metrolink crash that killed 24 individuals and injured over 100 people. As Liaison Counsel, Mr. Kiesel coordinated the successful resolution of the cases for $200 million, the maximum recovery allowed by law. Mr. Kiesel was Liaison Counsel for the Porter Ranch Environmental claims affecting over 38,000 individuals. The matter resolved in 2022 for $1.8 billion. Mr. Kiesel is also Co-Lead Plaintiffs’ Counsel of the JUUL Labs Product Cases.

Currently, Paul Kiesel represents many individuals and their families in significant personal injury and wrongful death cases. Among his many clients, Mr. Kiesel represented former Governor Gray Davis in a challenge to the qualification of the 2003 recall election.

Mr. Kiesel is also a frequent presenter for continuing legal education programs. As an early-adopter of technology in the practice of law, Mr. Kiesel has frequently written and spoken on technology-related subjects. In addition, he co-authored two legal treatises for Lexis Nexis, “California Pretrial Civil Procedure” and “California Civil Discovery.”