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Leading authority on the topic states that the phrase ?in limine? has been fully anglicized and thus is no longer is italicized. @BryanAGarner (editor in chief, Black's Law Dictionary), Twitter (Jan. 17, 2017, a.m.).
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.
The purpose of a motion in limine is to obtain an advance ruling on the admissibility of evidence that may be inadmissible or prejudicial, in order to avoid the possibility of a mistrial. A motion in limine may also be used to request an order prohibiting the mention of certain evidence in the presence of the jury.
Stated in the most general terms, a proper motion in limine is an evidentiary motion that seeks a determination as to whether to exclude (or admit) evidence before it is offered at trial.
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.