TBD | How-To Draft a Motion in Limine in Federal Court
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How-To: Write a Motion in Limine


Background: Your civil opponent will likely introduce certain evidence at trial
Problem: That evidence is bogus and harmful
Solution: You ask the Court to prevent the use of that certain evidence at trial

I. Definitions

In Limine
"Lat.: at the beginning or the threshhold. see motion in limine" Motion In Limine
"a motion used to exclude reference to anticipated evidence claimed to be objectionable until the admissibility of the questionable evidence can be determined either before or during the trial by presenting the court, out of the presence of the jury, offers and objections to the evidence. The motion seeks to avoid injection into trial of irrelevant, inadmissible, or prejudicial evidence at any point, including the voir dire examinations, opening statements, and direct and cross-examinations, and therefore prevents mistrials based on evidentiary irregularities."

II. Legal Citations

Rule 1 Fed. R. Civ. P. | Scope and Purpose
These rules govern the procedure in all civil actions and proceedings in the United States district courts, except as stated in Rule 81. They should be construed, administered, and employed by the court and the parties to secure the just, speedy, and inexpensive determination of every action and proceeding.
Rule 402 Fed. Evid. | General Admissibility of Relevant Evidence
Relevant evidence is admissible unless any of the following provides otherwise:
• the United States Constitution;
• a federal statute;
• these rules; or
• other rules prescribed by the Supreme Court.
Irrelevant evidence is not admissible.


Rule 403 Fed. Evid. | Excluding Relevant Evidence for Prejudice, Confusion, Waste of Time, or Other Reasons
The court may exclude relevant evidence if its probative value is substantially outweighed by a danger of one or more of the following: unfair prejudice, confusing the issues, misleading the jury, undue delay, wasting time, or needlessly presenting cumulative evidence.

III. Samples

# PDF Comments
1± TBD case. Pro Se Filing. USFLMD. Perjury from a State Officer.
2✓ Granted | USFLMD | 2019 | Attorney Filing | Hearsay evidence explicitly prohibited by statute
3✓ Granted | USFLMD | 2018 | Attorney Filing | Judicial Estoppel
4¿? Unknown Outcome | Duval | 2012 | Attorney Filing | Plaintiff's Summmary, Fraudulent Transfer
5✓ Partially Granted | DOAH | 2016 | Attorney Filing | Florida Bar complaints, Code Enforcements...
6✓ Partially Granted | DOAH | 2018 | Attorney Filing | Iowa Bid Protest

IV. Templates

# Word Comments
1USFLMD Version | Replace all placeholder tags (eg "[plfName]" becomes "John Doe").

V. Quick Commentary

VI. Conclusion

If you suspect your civil opponent will try to inject tainted/bogus evidence at trial then you can ask the Court to prevent that from happening.

Congratulations! You're now booked up on how to write a Motion in Limine!

Please get the justice you deserve.

Sincerely,



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