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Provide facts to support why the evidence should be excluded or admitted. Provide a legal explanation why the evidence is properly excluded or admitted. Cite supportive legal authority. Any oppositions to motions in limine should also be direct and clear.
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.
Motion to Suppress ? an attempt to keep certain statements or evidence from being introduced as evidence.
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.
Rule 404(a) provides, in pertinent part, that "Evidence of a person's character or a trait of his character is not admissible for the purpose of proving that he acted in conformity therewith on a particular occasion, except: (1) Character of an accused Evidence of a pertinent trait of his character offered by an ...
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.
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.