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Your motion in limine should be broken into two sections: (1) Factual Background and (2) Argument. The ?Factual Background? section of your Memorandum should include all of the facts necessary for the judge to resolve every issue raised in your motion. appropriate, include procedural posture, as well.
Typically, in a motion in limine (Latin for "at the start" or "on the threshold"), a party seeks to exclude prejudicial or irrelevant evidence from a jury trial. However, a party also may use a motion in limine to obtain an advance ruling on whether the court will admit specified evidence at trial.
Defense Motions in Limine Preclude doctor testifying against a nurse. Preclude expert testifying about future surgeries. Preclude evidence defendant driver was underinsured or even mentioning the uninsured motorist carrier. Motion to exclude videos depicting a below-knee amputation.
The most common use of the in limine motion is to exclude irrelevant and/or prejudicial evidence.
Most motions in limine are filed by a party to limit or prevent certain evidence from being presented by opposing counsel at the time of trial. The purpose of a motion in limine is to prevent the introduction of matters at trial which are irrelevant, inadmissible or prejudicial.