How has the issue of third party culpability been dealt with in a civil case?

The issue of third party culpability evidence first surfaced when the prosecution sought a ruling prior to jury voir dire excluding any such evidence. The motion was denied without prejudice at that time. The matter resurfaced in anticipation of references to such evidence in defendant's opening statement, which was never forthcoming, and became the subject of a full hearing pursuant to People v. Hall (1986) 41 Cal.3d 826, 226 Cal.Rptr. 112, 718 P.2d 99 (Hall) at the close of the People's case-in-chief.