I've included a recent filing in a multi-million dollar shareholder/fiduciary claim case. In this instance, note the abridged nature of the summary, the inclusion of a chart characterizing the over 400 pages of evidence, and the argument against their witness. The rule that governs motions in limine is Federal Rules of Civil Procedure 402 and 403, which gives the Court jurisdiction to include (402) and exclude (403) any evidence. Remember -- a motion in limine is an argument based on the rules of evidence. Most of the time, your motion will be heard at the pre-trial conference, but must be filed according to the scheduling order.
One last note -- be sure to provide an alternative remedy of "caution". This lays the foundation for attacking and seeking sanctions if your opponent engages in improper evidence submission during trial, after having been cautioned not to do so via your motion in limine.
Do you have a question about Court procedure, motions in limine, or pre-trial strategy? Call us! WE CAN HELP! 703-402-2723 or 1-800-579-8864.
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