Tip for Motions in Limine: Keep a Running List and Update It During Depositions

Don't wait until the eve of trial to put together your motion in limine. If you wait until the last minute, you're certain to forget to list items of evidence you should be arguing aren't admissible.

A better idea is to start a list of disputed evidentiary points at the very beginning of the case. Add to the list as the case proceeds. If you're like me, you'll make most of your entries as you take and defend depositions, as it's during depositions that most disputed evidentiary points are first previewed for you by your opposing counsel.

When it comes time to put together your motion in limine, you won't be starting from scratch. You'll have a list of case-specific ideas already composed, which you can add to your usual generic points.

Related posts:

1. A Sample Motion in Limine: Defense Version

2. A Sample Motion in Limine: Plaintiff's Version

3. Motions in Limine Seeking Admission of Evidence

Comments

[Ron Miller]

Evan, if your readers are looking for more motions in limine, we have more motions on our site: http://www.millerandzois.com/samplemotions.html

Ron Milller
www.Marylandinjurylawyerblog.com

[celia]

I'd heard this advice before, but your post refreshed my memory. Keeping a running track of anything that has the potential to be included in a motion in limine is one of the best tips ever. This blog continues to have some of the best information and advice about litigation that I've seen on the web.