Motions in limine must be filed at least 5 business days before the final pretrial conference.

Any objections to a motion in limine must be filed by the time of the final pretrial conference. A party may raise as many issues in a motion in limine as the case makes appropriate, but only one motion can be filed. Motions should identify the evidence at issue with specificity. Oral motions in limine will be allowed only for good cause shown.

Judge Van Bokkelen views rulings on motions in limine as preliminary. Judge Van Bokkelen declines to grant motions in limine unless the moving party faces a significant risk of irreparable harm if the motion is not granted. Because orders in limine are enforceable by contempt, Judge Van Bokkelen denies motions that would allow reasonable minds to differ on what evidence is covered. Accordingly, Judge Van Bokkelen is less likely to grant a motion in limine directed to broad categories of evidence (e.g., “evidence relevant only to punitive damages”) than one directed to a specific class of evidence (e.g., “evidence of the defendant's net worth”). A motion in limine should indicate why the movant thinks the targeted evidence might be offered, why the movant believes the targeted evidence will be inadmissible, and what injury the movant risks if an in-trial objection is required.