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Course Details

Course Information
  • smart_display Format

    Live Online with Live Q&A

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Insurance

Date & Time
  • event Date

    Tuesday, July 8, 2025

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

$297.00
CLE
ALL

This CLE course will guide insurer and policyholder counsel on effective use of motions in limine in insurance coverage litigation, including certain key issues to address, pitfalls to avoid, strategic considerations, and best practices for responding.

Faculty

Frederick Petti
Partner
Petti and Briones

Mr. Petti is a Partner at Petti and Briones PLLC. He is licensed to practice in Arizona, Oregon and Texas, he received his undergraduate degree from Arizona State University (B.A., History 1980), his Master’s Degree from Northern Arizona University (M.A., History 1982), and his law degree from the University of Arizona (J.D. 1987).

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Description

Effective motions in limine prevent a jury from even learning about improper or inadmissible evidence that would be unfairly prejudicial. But they may also seek affirmative determination that certain evidence will be admitted. In insurance coverage litigation, the defense may seek to prohibit certain types of expert testimony or testimony on topics related to insurance practices. Plaintiffs may seek to exclude testimony or documents related to irrelevant or extraneous personal information.

Motions in limine and each potential outcome must be evaluated in the context of the entire trial, including possible appeals. Educating the judge also educates opposing counsel. A motion that disposes of an entire claim or defense may actually do nothing more than create harmful error and guarantee reversal. Because motions in limine are determined before the trial starts based on "expected" evidence, rulings can change as evidence is presented or the judge or counsel change.

Assuming motions in limine are strategically warranted, they should be carefully prepared. Nothing annoys more than boilerplate, over-broad motions about generic evidence that is simply unfavorable.

Listen as our panel of experienced litigators guides counsel in best practices and strategies for effective use of motions in limine in insurance coverage litigation.

Outline

I. Overview of motions in limine

II. "Offensive" or proactive use of motions in limine

III. Key motion in limine issues in insurance overage litigation

A. Expert testimony

B. Insurance practices and protocols

C. Irrelevant personal, medical, or financial history

D. Unqualified or unreliable witnesses

E. Inflammatory material

IV. Strategic considerations

V. Mistakes to avoid

VI. Responding to motions in limine

Benefits

The panel will review these and other issues:

  • When should counsel consider the plaintiff's use of motions in limine?
  • When is the best time to submit the motions?
  • How can using motions in limine backfire?