Motion to Exclude Subsequent Events

IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND

PEOPLE’S ALTERNATIVE SVC SYS, INC - Plaintiff
v
MAYOR, CITY OF BALTIMORE - Defendant

CASE NO. 24-C-02-00380

Plaintiff, People’s Alternative Service Systems, Inc.’s Motion in Limine to Exclude Evidence Concerning the Activites of Plaintiff After the Relevent Events in this Case

Plaintiff, People’s Alternative Service Systems, Inc., by and through its undersigned counsel, moves in limine to exclude evidence of Plaintiff’s that is extrinsic to the contracts that are the subject of this lawsuit. In support, Plaintiff states as follows:

Defendant has indicated that it may seek to introduce at evidence regarding the activities of the Plaintiff since the contracts at issue were terminated. Plaintiff was and is a 501(c)(3) non-profit company. Since Defendant terminated its second contract with Plaintiff, it has not been able to procure significant grant money, thereby substantially limiting the scope and the breath of its activities. Plaintiff believes that Defendant will seek to introduce this evidence in an effort to distract the jury from the relevant issues. This information is not relevant for the jury to make the determination as to whether this contract was breached and wrongfully terminated. Even if this Court were to find that this evidence was relevant, its prejudice far outweighed its probative value. The danger of this evidence is that the jury would award less damages because it does not believe that PASS continues to be an operation non-profit when in fact the opposite is true.

Accordingly, Plaintiff requests an order that Defendant is preclude from offering or seeking evidence of the activities and operations of Plaintiff after the City terminated it contract with PASS on May 2, 2002.

Respectfully submitted,
MILLER & ZOIS, LLC

Ronald V. Miller, Jr.
1 South St, #2450
Baltimore, MD 21202
(410)779-4600
(410)760-8922 (fax)

Certificate of Service

I hereby certify that a copy of the foregoing Motions in Limine has been served upon the following counsel of record, via facsimile this 2nd day of September, 2003:

Kurt Heinrich, Esquire
Baltimore City Law Department
100 N. Holliday Street, Room 108
Baltimore, Maryland 21202
410-547-1025
Attorney for Defendant

Ronald V. Miller, Jr.

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