Motion in Limine Template
An Exhibit Register that gives every number on the joint list a disposition, plus the motions and the ruling tracker that come out of it.
Free download · No account needed
Thorncastle Instruments v. Bellweather Forge · Exhibit Register
Every number on the joint list, and the answer next to it
Illustrative rows from a fictional casting failure matter. Bellweather is the defendant supplier and trial is six weeks out.
| Ex. | Description | Produced | In 26(a) | Sponsor on a list | Disposition | Rule |
|---|---|---|---|---|---|---|
| TX-051 | Photographs of the failed housing, undated | No | No | None | Moved in limine | 37(c)(1) |
| TX-088 | Supplier scorecard covering four vendors | Yes | Yes | Iyengar, on neither | Moved in limine | 901(a) |
| TX-103 | Redesign drawing issued after the recall | Yes | Yes | Aldworth | Moved in limine | 407 |
| TX-014 | Internal quality memo, second casting lot | Yes | Yes | Aldworth | Objection reserved | 803(6) |
| TX-171 | Email chain on the March pricing dispute | Yes | Yes | Hollings | No objection | |
| BW-601 | Settlement note to the third supplier | Yes | Yes | Marsom | Withdrawn 14 Mar | 408 |
The three middle columns are the ones nobody else has
TX-051 and TX-088 are unremarkable on their faces. One is a photograph and the other is a scorecard, and reading either tells you nothing. They are motions because of what is missing from the production log and the witness lists, which is a fact about two other documents.
| Disposition | Exhibits | Share |
|---|---|---|
| No objection | 209 | 50.7% |
| Objection reserved for trial | 123 | 29.9% |
| Moved in limine | 63 | 15.3% |
| Withdrawn after the meet and confer | 17 | 4.1% |
| Joint list, every number accounted for | 412 | 100% |
An empty disposition cell is the failure this sheet exists to prevent. 412 exhibits inside a 14 day objection window is 29.4 a day, weekends included.
A motion in limine template gives you the form of one motion, and the drafting is the easy half. The hard half is which of the 412 exhibits on the Thorncastle Instruments v. Bellweather Forge joint list needs one. Pretrial disclosures land at least 30 days before trial, and an objection not served within the next 14 days is waived except under Rules 402 and 403. That is 29 exhibits a day including the weekend, so the register is filled by joining lists rather than by reading documents.
Three columns do work no drafting guide does. Was this exhibit produced, with a Bates number in the production log? Does it appear in a Rule 26(a) disclosure? Is anyone who could authenticate it on a witness list? Twenty-two exhibits fail the first two, and a party that fails to disclose may not use that evidence at trial unless the failure was harmless. Nineteen fail the third. Those two joins produce 41 of the 63 exhibits moved on, and no document shows it on its face.
Eleven motions come back from the pretrial conference, seven granted and four not, which reads like a good afternoon. Once the court rules definitively on the record a party need not renew an objection or offer of proof, so the two definitive denials are finished and the three provisional grants are not. Six rulings are closed across 43 exhibits and five are live across 20, each carrying a named lawyer and the sentence they say while the exhibit is handed to a witness.
What's in the pack
Exhibit Register
One row per exhibit, carrying the disposition, the ground, the rule, and the three columns that produce the motions.
Designation Index
Every designated block joined back to the exhibit it discusses, so an exclusion cannot leak through a deposition digest.
Ruling Tracker
Each ruling on two axes, and every live row names what happens at trial, who does it, and the exact words.
Motions in Limine
One motion per way an exhibit fails, with the numbers listed out, because a category is something a court has to guess at.
Opposition Preparation
Their motions answered at the exhibit level, with the position we cannot defend marked as one rather than argued.
Offers of Proof and Trial Objections
The live rulings as a printed script, plus a drafted offer of proof for each piece of your own evidence kept out.
What a Ruling Actually Preserves
Why the tracker sorts on definitive rather than granted, and what counts as definitive when the minute order is ambiguous.
How to use it
- 1
Open in River, or take it blank
Hand River the joint exhibit list, both witness lists, the designations, the production log and the disclosures, or take the Word documents and CSV sheets from the template library.
- 2
Every exhibit, then the joins
One row per exhibit before any motion is drafted, then the list joined against the production log, the Rule 26(a) disclosures and both witness lists.
- 3
Group by how the exhibit fails
One motion per evidentiary basis with the numbers listed, checked against the standing order that says whether this court wants an omnibus filing or separate motions.
- 4
Record the ruling on two axes
Definitive or provisional first and granted or denied second, and every live row gets a named lawyer and the sentence they will say. That first column is what the appellate record and brief pack reads a year later.
Frequently asked questions
Is this template free?
Free, no account, no card. The download is four Word documents and three CSV sheets. The AI branch does what the blank files cannot: it reads your joint list against your production log and your disclosures, then reports the exhibits neither one accounts for. Every other pack in the template library opens the same two ways.
What format are the downloaded files?
One zip, with the four documents as Word (.docx) and the three registers as CSV (.csv). The registers open in Excel, Numbers or Google Sheets, and the motions, the opposition notes, the offers of proof and the method doc open in Word or Pages. No conversion, nothing proprietary.
One omnibus motion, or a separate motion for each issue?
The judge's standing order decides it, and both camps are real. The individual rules of Chief Judge McMahon in the Southern District of New York ask counsel to file each application separately, with a brief of no more than five pages. Other chambers want one numbered document, and the local formatting layer gets read the same way.
How does it decide which exhibits need a motion?
By joining lists rather than by reading documents. An exhibit with no Bates number in the production and no mention in a disclosure is a Rule 37(c)(1) motion. An exhibit whose only sponsor is on neither witness list is an authentication motion. Those two joins found 41 of the 63, and the other 22 came from grading the record proposition by proposition.
Does a granted motion in limine settle the issue?
Not when the grant carries a condition. A definitive ruling on the record relieves a party of renewing the objection or the offer of proof, and a grant subject to a foundation being laid is not one. Three of the seven grants in the worked matter are conditions, covering 17 exhibits somebody still has to object to in the moment.
Do the deposition designations need their own motions?
Often, and it is the step that gets missed. Excluding an exhibit does not exclude the testimony that reads its contents to the jury. In the worked matter 108 designated lines across three witnesses discuss an exhibit that was excluded, and each block needs a motion to strike filed alongside the exhibit motion.
What does Edit with AI actually do?
It creates the account, installs this pack as a private workspace, and leaves the agent waiting on an empty Exhibit Register. Send the joint list, both witness lists, the designations, the production log and the Rule 26(a) disclosures. What comes back first is the set of exhibits nothing accounts for, with the authority behind each ground.
Start from the exhibit list, not from a list of motions
Take the Word documents and CSV sheets blank, or open the pack in River with your own joint list and designations in it.
Edit with AI