Equinox F&B, Inc. v. Roots Pressed Juices LLC

Background

Equinox filed motions in limine, which are requests made before trial to limit or exclude evidence. The motions concerned evidence that Roots Pressed Juices LLC might offer about its claimed damages and alleged theft from the Roots cafes. The court also relied on reasons stated during the March 18, 2024 conference.

Rulings on the Evidence

The court denied Equinox’s request to categorically exclude Roots’s damages evidence. Equinox argued that the evidence was inadmissible hearsay. The court explained that an invoice or other business record may be admitted for the truth of its contents if a custodian or another qualified witness testifies under oath that the document was prepared during regularly conducted business activity and that creating such documents was the business’s regular practice. Roots represented that Mr. Rodgers could provide that foundation. The court therefore found no reason to exclude the documents before trial. Equinox may renew its objection at trial, and the documents will not be considered if Roots cannot establish their admissibility.

The court also denied Equinox’s request to exclude testimony about alleged theft from the Roots cafes. The court found that the testimony had at least some possible relevance. Because the case will be tried without a jury, the court said there was no concern about juror confusion or potential prejudice. Equinox may object at trial if Roots does not demonstrate relevance, and the court will consider the objection when deciding what weight, if any, to give the evidence.

Disposition

Judge Arun Subramanian denied without prejudice Plaintiff’s motions in limine. The clerk was directed to terminate the motion at docket entry 71.