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You should explain why the other side's motion in limine should be denied and why you should be free to introduce the evidence at trial if you choose. Try to support your argument with citations to court rules or to case opinions which support your argument.
Generally, a motion in limine is used to exclude evidence that a party believes to be irrelevant or unfairly prejudicial. Often, motions in limine may also be dispositive in nature by seeking to exclude evidence necessary to prove a key aspect of an opponent's case.
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.
Motions in limine should be carefully drafted to make clear precisely what evidence should be excluded and to explain with as much clarity as possible why the inadmissible evidence is so damaging that its mere mention would be unfairly prejudicial.
A motion in limine is decided by the judge outside of the presence of the jury. The purpose of a motion in limine is to address potentially prejudicial, irrelevant, or inadmissible information that could unduly influence a jury or hinder the fair administration of justice.