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Let's start with a motion in limine included in virtually every set defense attorneys in Georgia file: a prohibition on so-called Golden Rule arguments, in which a trial attorney asks the jury to place themselves in the plaintiff's shoes.
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.
As a true motion in limine, it merely requested that the State not be permitted to mention any evidence of prior convictions to the jury until a hearing had been held outside the presence of the jury to determine their admissibility. That is precisely the proper purpose of a motion in limine.
Golden rule argument is an argument made by a lawyer during a jury trial to ask the jurors to put themselves in the place of the victim or the injured person and deliver the verdict that they would wish to receive if they were in that person's position.
Rule 91. Special Exceptions (Mar1941) A special exception shall not only point out the particular pleading excepted to, but it shall also point out intelligibly and with particularity the defect, omission, obscurity, duplicity, generality, or other insufficiency in the allegations in the pleading excepted to.
The most common use of the in limine motion is to exclude irrelevant and/or prejudicial evidence.
The golden rule arises out of two fundamental principles: that courts must interpret statute "ing to the intent of them that made it", and that "the words of the statute speak the intention of the Legislature".
A general denial of matters pleaded by the adverse party which are not required to be denied under oath, shall be sufficient to put the same in issue.