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Motions in Limine for Insurance Coverage Litigation: Key Issues, Strategic Decisions, Pitfalls to Avoid, Responding

A live 90-minute CLE video webinar with interactive 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.

Tuesday, July 8, 2025

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

Early Registration Discount Deadline, Friday, June 20, 2025

or call 1-800-926-7926
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This CLE course will guide insurer and policyholder counsel on effective use of motions in limine in insurance coverage litigation, including certain key issues to address, pitfalls to avoid, strategic considerations, and best practices for responding.

Description

Effective motions in limine prevent a jury from even learning about improper or inadmissible evidence that would be unfairly prejudicial. But they may also seek affirmative determination that certain evidence will be admitted. In insurance coverage litigation, the defense may seek to prohibit certain types of expert testimony or testimony on topics related to insurance practices. Plaintiffs may seek to exclude testimony or documents related to irrelevant or extraneous personal information.

Motions in limine and each potential outcome must be evaluated in the context of the entire trial, including possible appeals. Educating the judge also educates opposing counsel. A motion that disposes of an entire claim or defense may actually do nothing more than create harmful error and guarantee reversal. Because motions in limine are determined before the trial starts based on "expected" evidence, rulings can change as evidence is presented or the judge or counsel change.

Assuming motions in limine are strategically warranted, they should be carefully prepared. Nothing annoys more than boilerplate, over-broad motions about generic evidence that is simply unfavorable.

Listen as our panel of experienced litigators guides counsel in best practices and strategies for effective use of motions in limine in insurance coverage litigation.

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Outline

  1. Overview of motions in limine
  2. "Offensive" or proactive use of motions in limine
  3. Key motion in limine issues in insurance overage litigation
    1. Expert testimony
    2. Insurance practices and protocols
    3. Irrelevant personal, medical, or financial history
    4. Unqualified or unreliable witnesses
    5. Inflammatory material
  4. Strategic considerations
  5. Mistakes to avoid
  6. Responding to motions in limine

Benefits

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 using motions in limine backfire?

Faculty

Petti, Frederick
Frederick Petti
Partner
Petti and Briones

Mr. Petti is a Partner at Petti and Briones PLLC.  He is licensed to practice in Arizona, Oregon and...  |  Read More

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Early Discount (through 06/20/25)

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Early Discount (through 06/20/25)

You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. Strafford will process CLE credit for one person on each recording. All formats include course handouts.

To find out which recorded format will provide the best CLE option, select your state:

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