If You Can't Explain Your In Limine Motion Simply, It is Not Likely to Be Granted.

Here's an interesting standard Judge King lays out for an in limine motion -- if you can't explain it simply to the Court pretrial, it's not something the Court should be ruling on pretrial:
In limine consideration of arguments and evidence relating to the Defendants' "strategic planning and strategic planning documents'' is equally misplaced. One need look no further than Defendants' memorandum (pp. 6-10 - D.E. #84) to quickly discern that the complexities of even describing this issue to the Court pretrial renders it not a matter which should be considered in limine. Experienced trial counsel, and certainly the Court, can envision perhaps a half a dozen ways in which these matters might be relevant during the trial presentation of evidence. Counsel will have the full opportunity to make whatever objection they wish to make - materiality, relevancy, work product, etc. - if, and when, the evidence is sought to be presented.
Simplify, simplify, simplify!


  1. Joint FAIL by Podhurst + Greenberg.

  2. Happy Friday, SFL!

  3. Judge King does not favor motions in limine---EVER.

  4. This is great. One of the things that has been really beneficial about my experience where I am with lawyers calgary is that they do present everything so simply and help me understand what exactly is going on which really inspires a lot of confidence.


Post a Comment