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Motions in Limine: Admitting Key Evidence, Educating the Court, Capturing Settlement Leverage

Recording of a 90-minute CLE webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Tuesday, December 8, 2020

Recorded event now available

or call 1-800-926-7926

This CLE course will offer counsel new appreciation of the power and versatility of motions in limine to alter the course of litigation. The panel will guide counsel in how to use them proficiently and proactively to not only obtain rulings on critical pieces of evidence but also to educate the court and glimpse the strengths and weaknesses of opposing parties. The panel will also address best practices when responding to "boilerplate" and bespoke motions.


Attorneys typically offer motions in limine to exclude unfavorable evidence, usually on the eve of trial. But motions in limine can also request an affirmative ruling that specific evidence will be admitted, certain objections overruled, and teach trial counsel a lot about the adversary's case.

Early motions in limine can capture the attention of busy judges before trial, increasing the likelihood of a favorable ruling. They can also prohibit improper lines of arguments, and when done correctly, foreclose "reptile" arguments. But omnibus, boilerplate motions may receive scant attention. Counsel must be aware of how the judge's decision granting, denying, or postponing the motion impacts the rest of the trial and preservation of error.

Likewise, when responding to motions in limine, trial counsel must be vigilant to avoid missing dispositive motions disguised as a motion to exclude and know when to acquiesce.

Listen as our panel of experienced litigators guides counsel in best practices and strategies for taking advantage of this often underused and unassuming but powerful tool.



  1. Overview of motions in limine
    1. Authority
    2. Standards for determining
    3. Reconsideration
    4. Effect of grant or denial
  2. What constitutes the "offensive" or proactive use of motions in limine
    1. Benefits
    2. Risks
  3. Strategic considerations
    1. Timing of the motions
    2. Best practices in drafting motions
    3. Crafting the scope of relief
  4. Responding to motions in limine


The panel will review these and other issues:

  • When should counsel consider the plaintiff's use of motions in limine?
  • When is the best time to submit the motions?
  • How can the movant make the court's ruling easier?
  • What can counsel learn from the opposing parties' case from their responses?


McKirgan, Robert
Robert H. McKirgan

Practice Group Leader, Partner
Lewis Roca Rothgerber Christie

Mr. McKirgan practices primarily in the area of business, intellectual property and bankruptcy-related litigation. He...  |  Read More

Petti, Frederick
Frederick Petti

Petti and Briones


 |  Read More

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