[COURT NAME]
[DIVISION] DIVISION

[PLAINTIFF NAME(S)], §
§
Plaintiff[s], §
§ CIVIL ACTION NO. [CASE NO.]
v. §
§
[DEFENDANT NAME(S)], §
§
Defendant[s]. §
________________________________________________§______________________________________________

[MOVING PARTY] MOTION IN LIMINE
________________________________________________________________________________________________

[// GUIDANCE: Insert any required local-rule header language here.]

NOTICE OF MOTION AND MOTION

PLEASE TAKE NOTICE that on [HEARING DATE] at [TIME], or as soon thereafter as counsel may be heard, [MOVING PARTY] will and hereby does move the Court for an order excluding the evidence and argument described below.

MEMORANDUM OF POINTS AND AUTHORITIES

I. Introduction

[Briefly state the categories of evidence to be excluded and why exclusion is necessary.]

II. Legal Standard

Evidence must be relevant and its probative value must not be substantially outweighed by the danger of unfair prejudice, confusion, or waste of time. See [STATE RULE OF EVIDENCE 403 / FED. R. EVID. 403].

III. Argument

A. Exclude evidence of [CATEGORY 1].
[Explain why the evidence is irrelevant, inadmissible, or unduly prejudicial; cite rules and case law.]

B. Exclude evidence of [CATEGORY 2].
[Explain why the evidence is inadmissible; address hearsay, character evidence, or other grounds.]

C. Exclude evidence of [CATEGORY 3].
[Add additional categories as needed.]

IV. Requested Relief

[MOVING PARTY] respectfully requests that the Court:
1. Exclude the categories of evidence described above.
2. Instruct counsel and witnesses to refrain from referencing excluded matters in front of the jury.
3. Require prior notice and sidebar before any party seeks to introduce excluded evidence.

CONCLUSION

For the foregoing reasons, the Court should grant the Motion in Limine.

Respectfully submitted,

text
Dated: [DATE]

______________________________
[ATTORNEY NAME]
[LAW FIRM]
[ADDRESS]
[PHONE]
[EMAIL]
Attorney for [MOVING PARTY]

CERTIFICATE OF SERVICE

I certify that on [DATE], I served the foregoing Motion in Limine on all counsel of record via [METHOD OF SERVICE] in compliance with applicable rules.

text
______________________________
[ATTORNEY NAME]

[PROPOSED] ORDER

The Court, having considered [MOVING PARTY]'s Motion in Limine, the supporting papers, and any opposition, ORDERS as follows:
1. The Motion is GRANTED.
2. The categories of evidence identified above are excluded.
3. Counsel and witnesses shall comply with this Order.

IT IS SO ORDERED.

Dated: [DATE]

______________________________________
[JUDGE NAME]
[TITLE]