Motion in Limine Outline for a Personal Injury Trial, Evidence Item by Item
Outlines motions in limine item by item: the evidence, the ground, the authority you supplied or a flag where authority is needed, the record foundation, the anticipated opposition and proposed order language.
The Prompt
Variables (7)
| Variable | Description | Example |
|---|---|---|
| {{court_and_jurisdiction}} | Court and Jurisdiction | Circuit Court for Davidson County, Tennessee (state court) |
| {{governing_evidence_rules}} | Governing Evidence Rules and Pretrial Order | Tennessee Rules of Evidence 401, 402 and 403 (text pasted below). Pretrial order dated 12/01/2025: motions in limine due per paragraph 6; one consolidated filing, 15-page limit. |
| {{trial_date}} | Trial Date | 2026-03-09 |
| {{evidence_items}} | Evidence Items | 1. EXCLUDE: reference to plaintiff's 2017 workers' compensation claim for a wrist injury (irrelevant, prejudicial). 2. EXCLUDE: IME opinion on "secondary gain". 3. ADMIT: Sunline telematics report SUN000201. |
| {{supplied_authority}} | Verified Authority | Rule 403 text as pasted above. No case law verified yet for item 2. |
| {{anticipated_defense_arguments}} | Anticipated Defense Arguments | Defense pretrial statement, p. 4: the 2017 claim "bears on credibility and prior complaints of pain." |
| {{record_excerpts}} | Record Excerpts | Plaintiff deposition 10/02/2025, 71:5-18 (2017 claim, right wrist, closed 2018). Whitfield report 11/20/2025, p. 11: "secondary gain cannot be excluded." Sunline custodian deposition 01/08/2026, 15:2-20. |
Expected Output
Seven parts: (A) a summary table of every item with the attorney's ground, the fit check, the authority status and a rank; (B) conflicts between sources and recomputed figures from the record excerpts; (C) for each item, the evidence, the ground and whether the record supports it as stated, the authority supplied or flagged as needed, the foundation quoted from the record, the opposition and reply, the scope, and proposed order language; (D) items better left to trial objection, only where your inputs say so; (E) unsupported statements declined; (F) declined requests; (G) missing information. A verification list closes the output.
Usage Notes
Use when the pretrial order sets the motion schedule and you know what evidence each side intends to offer. List each item with "exclude" or "admit" and your ground, paste the record passages that prove the evidence exists, and paste only authority you have read. Failure modes to watch for: a ground a quoted record passage contradicts (only then does the fit check say No and leave the order language for you to complete), and a ground that sounds right but has no supplied authority behind it; every authority-needed flag is research still owed, and a case cited only in the defense's papers must be pulled and read before you answer it. The federal rules listed are reference points and do not govern a state-court trial. Not legal advice. The attorney remains responsible for verifying every fact, figure and authority before use.
Legal Sources Referenced
- Fed. R. Evid. 403 (the court may exclude relevant evidence if its probative value is substantially outweighed by a danger of unfair prejudice, confusing the issues, misleading the jury, undue delay, wasting time, or needlessly presenting cumulative evidence)
- Fed. R. Evid. 103(b) (once the court rules definitively on the record, either before or at trial, a party need not renew an objection or offer of proof to preserve a claim of error for appeal)
Originally featured in: AI for Personal Injury Lawyers: Prompts for Demand Letters, Medical Summaries & Depositions
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* These prompts are drafting and analysis aids for licensed attorneys. They are not legal advice and do not replace professional judgment. AI output can contain errors, including invented citations and incorrect deadlines: verify every fact, figure, authority and deadline against primary sources before relying on it. Rules vary by jurisdiction, and you remain responsible for the final work product.