Motions in Limine in Personal Injury: Obtaining Early Rulings on the Exclusion or Admissibility of Certain Evidence

Evaluating Whether and When to File Motion in Limine; Strategies for Researching, Drafting and Arguing Motions

*** This program has been cancelled ***

A live 90-minute CLE webinar with interactive Q&A

Wednesday, May 31, 2017 (in 3 days)
(Alert: Event date has changed from 3/22/2017!)
1:00pm-2:30pm EDT, 10:00am-11:30am PDT

This CLE webinar will provide guidance to personal injury plaintiff and defense litigators on strategically using motions in limine to prevent the admission of prejudicial or irrelevant evidence or to obtain a ruling allowing for the admission of certain evidence. Our panel will discuss common pitfalls with motions in limine and explain how thoughtful crafting and arguing of motions in limine can help ensure that certain evidence is excluded or admitted at trial.


Strategically filed motions in limine can set the stage for success in personal injury trials by preventing unfavorable evidence from coming before the jury. Motions in limine can also be leveraged by personal injury litigators—both plaintiff and defense—to obtain advanced rulings on whether evidence critical to their position may be admitted.

When approached thoughtfully, motions in limine can be instrumental in helping counsel develop case themes and defining the parameters of a trial. Motions in limine can also serve as an effective tool for preserving issues for appeal.

Listen as our authoritative panel of personal injury litigators discusses how to strategically leverage motions in limine to exclude or admit certain evidence. The panel will explore recurring issues that arise with motions in limine in personal injury litigation and offer guidance on effectively researching, drafting and arguing motions in limine.


  1. Bringing motions in limine
    1. Evaluating whether to bring
    2. Timing of motion
    3. Researching motion
    4. Drafting motion
    5. Arguing motion
  2. Defending motions in limine
  3. Preserving issues for appeal after unfavorable ruling on motion in limine


The panel will discuss these and other key issues:

  • What types of evidence do personal injury attorneys generally seek to exclude via motions in limine?
  • What categories of evidence may warrant a motion in limine seeking to admit certain evidence?
  • What timing considerations should counsel take into account when filing motions in limine?
  • How should motions in limine be drafted and argued in court?
  • What steps should counsel take to preserve an objection for appeal following the denial of a motion in limine?


David H. Fleisher, P.E.
Fleisher Forensics, Ambler, Pa.

Mr. Fleisher has evaluated litigation and claim matters involving premises liability, highway, construction and accident reconstruction since 1986. He has been qualified to testify as an expert in federal and state courts. Before founding Fleisher Forensics in 2002, he was Vice President of Consulting Engineers and Scientists, Inc. for 16 years, where he evaluated litigation and claim matters. He frequently presents to attorneys at CLE programs. 

Matthew J. Focht, Senior Counsel
Joseph Greenwald & Laake, Greenbelt, Md.

Mr. Focht is a trial lawyer in the firm’s Personal Injury Practice Group. He helps individuals who have been seriously injured in avoidable accidents recover the compensation they deserve in litigation before state and federal courts. He has deep experience in managing a broad range of high-stakes personal injury matters on behalf of victims and surviving family members, including auto accidents, wrongful death cases, and a variety of other serious accidents caused by negligence.

Live Webinar

Live Webinar $197.00

Add a colleague on the same connection in the same room for only $97.00 in the shopping cart or by calling customer service.

This webinar is eligible for at least 1.5 general CLE credits.

CLE credits are not available for PR.

*In KS, OH, PA, for more than 1 attendee on the connection you must contact Strafford CLE via email or call 1-800-926-7926 ext. 35 prior to the program for special instructions.


CLE On-Demand - Streaming Video

Includes recorded streaming video of full program plus PDF handouts.

On-demand is the only recorded format recognized for CLE credits in DE, IN, KS, LA, MS, NC, OH, OK, SC, TN, VA, WI.

AK, AZ, CA, CO, CT, DE, FL, GA, HI, IA, ID, IL, IN*, KS, KY, LA, ME, MN, MO, MT, NC, ND, NH**, NJ, NM, NV, NY, OH*, OK, OR, PA, SC, TN, TX, UT, VA, VT, WA, WI, WV, WY (Note: Some states restrict CLE eligibility based on the age of a program. Refer to our state CLE Map for additional information.)

*Only available for attorneys admitted for more than two years. For OH CLE credits, only programs recorded within the current calendar year are eligible - contact the CLE department for verification.

**NH attendees must self-determine if a program is eligible for credit and self-report their attendance.

CLE On-Demand Video $197.00
Available 48 hours after the live event

How does this work?

Recorded Event

Includes full event recording plus handouts (available after live webinar).

Strafford is an approved provider and self-study CLE credit is available in most states.

AK, AZ, CA, CO, CT, FL, GA, HI, IA, ID, IL, KY, ME, MN, MO, MT, ND, NJ, NM, NY, OR, PA, TN, TX, UT, VT, WA, WV, WY (Note: Some states restrict CLE eligibility based on the age of a program. Refer to our state CLE Map for additional information.)

Strafford will process CLE credit for one person on each recording.

Additional copies of a recording can be purchased at a discount. Please call Strafford Customer Service toll-free at 1-800-926-7926 ext 10 or email to place your order.

Recorded Webinar Download $197.00
Available 48 hours after the live event

How does this work?

Recorded Audio Download (MP3) $197.00
Available 24 hours after the live event

How does this work?

DVD (Slide Presentation with Audio) $197.00 plus $9.45 S&H
Available ten business days after the live event

How does this work?

Registration Plus Recorded Event

Best value!

Live Webinar & Webinar Download $274.00

Recorded Webinar Download Only $77.00 with Registration/Webinar Combo

Live Webinar & Audio Download $274.00

Recorded Audio Download (MP3) Only $77.00 with Registration/MP3 Combo

Live Webinar & DVD $274.00 plus $9.45 S&H

DVD (Slide Presentation with Audio) Only $77.00 with Registration/DVD Combo


Strafford webinars offer several options for participation: online viewing of speaker-controlled PowerPoint presentations with audio via computer speakers or via phone; or audio only via telephone (download speaker handouts prior to the program).  Please note that our webinars do not feature videos of the presenters.

CLE Credits By State

See CLE State Map >

Customer Reviews

Overall, a very good presentation. For my practice, the presentation was relevant and highly informative.

David Lawrenz

Hinkle, Hensley, Shanor & Martin

I liked the practical and specific tips.

Natalie Lyons

The Cannon Law Firm

The relevance of the material and impact on the PI practice area was greatly appreciated.

Derek M. Baroumes

Baroumes & Bruen

The webinar was well-presented, interesting and informative.

Randi Saul-Olson

McKinney, Wainwright & Saul-Olson

Great content, including everyday examples, provided by each speaker.

Tim Reed

Duncan Firm

Litigation Advisory Board

David R. Cohen


Reed Smith

Jeffrey J. Fowler


O’Melveny & Myers

Jonathan Evan Goldberg


Vandenberg & Feliu

Mark E. Goodman


Capes Sokol Goodman & Sarachan

Dean D. Hunt


Baker & Hostetler

Michael E. Lackey, Jr.


Mayer Brown

Stephen Paffrath


Greenberg Traurig

Anthony T. Pierce


Akin Gump Strauss Hauer & Feld

Robert B. (Barry) Wiggins


Deloitte Financial Advisory Services

Our Guarantee

Strafford webinars are backed by our 100% Unconditional Money-Back Guarantee: if you are not satisfied with any of our products, simply let us know and get a full refund. For more information regarding complaints and refunds, please contact us at 1-800-926-7926 ext 10. Complaints regarding this program can be submitted via the course evaluation found in the “Thank you” e-mail at the end of the course.