# Motion in limine
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Draft and analyze motions in limine for US federal court proceedings.

Draft and analyze motions in limine for US federal court proceedings. Use when filing or opposing pretrial motions to exclude or limit evidence, preparing argument outlines for evidentiary hearings, anticipating opposition responses, or advising on evidentiary strategy before trial. Covers FRE 401-403 relevance and unfair prejudice balancing (Old Chief, Sprint/United Management), FRE 404(b) prior acts and crimes (Huddleston conditional relevance, 2020 notice amendment, inextricably intertwined doctrine), FRE 407-411 policy exclusions (subsequent remedial measures, compromise negotiations, medical payments, plea statements, liability insurance), FRE 501-502 privilege and inadvertent waiver (clawback orders, 502(d) federal-court orders), FRE 702 expert testimony and Daubert gatekeeping (2023 amendment, Joiner analytical-gap, Kumho Tire non-scientific experts), FRE 801-807 hearsay and exceptions (Crawford Confrontation Clause testimonial overlay, Davis primary-purpose test), and FRE 609 prior convictions for impeachment (crimen falsi mandatory admission, 10-year balancing). Includes standard opposition and response arguments, limiting instruction strategy under FRE 105, conditional relevance under FRE 104(b), door-opening doctrine, and offer-of-proof requirements. Generates argument outlines with confidence-scored authority, anticipated opposition arguments, and reply strategy with Glass Box audit trail.

This skill drafts and analyzes motions in limine in US federal courts — pretrial motions requesting advance rulings on the admissibility of specific evidence before trial. It operates in two primary modes: 1. **Drafting Mode**: Generates argument blocks, outlines, and supporting authority for a motion to exclude or limit specific evidence based on the FRE grounds selected. Produces a structured argument framework for attorney review and refinement into a final motion. 2. **Analysis Mode**: Evaluates a motion in limine the user has received — identifying the moving party's strongest and weakest arguments, assessing opposition viability, and developing response strategy including limiting instructions and alternative admissibility theories. **Covers:** - **FRE 401-403**: Relevance threshold, character evidence context, unfair prejudice balancing — including Old Chief stipulation doctrine, sprint/context-dependency rule, and 403 as "last resort" not "first resort" - **FRE 404(b)**: Other crimes, wrongs, or acts — propensity prohibition, permitted non-propensity purposes, 2020 notice amendment, Huddleston conditional-relevance standard, inextricably intertwined / direct evidence doctrine, Beechum two-step test - **FRE 407**: Subsequent remedial measures — admissibility carve-outs for ownership, control, feasibility, and impeachment; products liability nuances - **FRE 408**: Compromise negotiations — what is and is not protected, the bias/undue delay/obstruction exceptions, the "in connection ...

## Jurisdictions

Global



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