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A motion in limine is a procedural mechanism that allows litigators to seek to exclude certain evidence from being presented to a jury ? typically evidence that is irrelevant, unreliable, or more prejudicial than probative.
An example of a motion to suppress is where a defendant requests the court to suppress a confession by the defendant to the police that was obtained as a result of a Miranda violation.
Examples of motions in limine include a request by the defendant's attorney to exclude personal information, such as medical, criminal, or financial records, from being admitted as evidence. The attorney may argue that these records are irrelevant, immaterial, unreliable, or unduly prejudicial.
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.