Yarborough Applegate attorneys have a passion for sharing their expertise with the larger law community. Our own Chris Bryant shares his insights on making better motions in limine in the November issue of Trial magazine.
Chris writes:
…by not thinking about motions in limine until the last minute, we miss opportunities to strengthen our cases.
…Make sure your motions have substantive support.
In a recent case, opposing counsel’s deposition questions and requests for admission showed they intended to use our client’s incomplete tax returns and employment records to cast doubt on his lost wages and future earnings claim. By thinking about motions early, we compiled relevant case law to exclude evidence of his failure to file tax returns.
To read Chris’s full article, members can access it here.