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Golden Rule arguments are already well-known to judges. The court may be more receptive to motions in limine seeking to forbid any Golden Rule arguments, instead of banning ?Reptile Theory? wholesale. The classic Golden Rule argument asks jurors to place themselves in the shoes of another person.
For example, if you are involved in a DUI accident and discover that there is a witness who is inflating the details of the case, then your attorney may create a motion in limine that requests that that witnesses' testimony be thrown out before the case proceeds.
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.
For example, if you are involved in a DUI accident and discover that there is a witness who is inflating the details of the case, then your attorney may create a motion in limine that requests that that witnesses' testimony be thrown out before the case proceeds.
A "motion in limine" is a pretrial motion that seeks the exclusion of specific evidence or arguments from being presented during a trial. A motion in limine is decided by the judge outside of the presence of the jury.