and serve motions in limine with timely statutory notice so as to be heard on the day of final status conference, or at least five days before the final status confer- ence.
The Superior Court of Los Angeles,
Local Rules, rule 3.25 (h) (3) states that in master-calendar cases, parties must file and serve motions in limine, or at least five days before the final status con- ference to be heard on the first day of trial.
The Superior Court of Los Angeles,
Local Rules, rule 3.57 (a) requires that all motions in limine be accompanied by a declaration that includes: an identifica- tion of the specific matter alleged to be inadmissible and prejudicial; a statement of attempts made at informal resolution; the specific prejudice that will be suffered by the moving party; and, if the motion seeks to make a discovery response bind- ing, the declaration must set forth the question and answer and state why the use of the answer for impeachment will not adequately protect the moving party against prejudice. The Superior Court of Los Angeles,
Local Rules, rule 3.57 (b) limits the use of motions in limine as a summary judg- ment.
The Superior Court of Los Angeles, Local Rules, rule 3.57 (c) prohibits the
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use of such motions to bifurcate issue or issues.
The Superior Court of Los Angeles,
Local Rules, rule 3.57 (d) allows the court to defer ruling on the motion but may order that no mention of the matter be made until it decides otherwise. It is the duty of counsel to instruct client, wit- nesses, and expert and other persons under their control not to mention the matter in front of the jury. And if you are litigating in Ventura
County, beware of the two page rule! Once you have got over the shock, it can actually streamline a process which embodies the less is more rule.
Motions in limine come in bunches.
It is not unusual for a trial judge to be presented with literally dozens of in lim- ine motions – for each party – in a single case. Make your motion stand out from the pack. You will make the life of your judge, and your case, easier. As with all motion writing, less is often more. If the court is familiar with the general facts of the case, there is no need to recite a lengthy restatement of the case history. Write a direct and succinct first para- graph and get straight down the law and how it applies to your argument.
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877-695-6444 x89 FEBRUARY 2012 The Advocate Magazine — 83 FEBRUARY 2012 The Advocate Magazine — 83
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