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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.

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Pack of 7 files: 4 documents, 3 spreadsheets

Motion in Limine Template

Exhibit RegisterSpreadsheet
Designation IndexSpreadsheet
Ruling TrackerSpreadsheet
Motions in LimineDocument
Opposition PreparationDocument
Offers of Proof and Trial ObjectionsDocument
What a Ruling Actually PreservesDocument

Motion in Limine Template

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BW-601	Settlement note to the third supplier	Yes	Yes	Marsom	Withdrawn 14 Mar	408

Ex.

Description

Produced

In 26(a)

Sponsor on a list

Disposition

Rule

TX-051

Photographs of the failed housing, undated

None

Moved in limine

37(c)(1)

TX-088

Supplier scorecard covering four vendors

Yes

Iyengar, on neither

Moved in limine

901(a)

TX-103

Redesign drawing issued after the recall

Yes

Aldworth

Moved in limine

407

TX-014

Internal quality memo, second casting lot

Yes

Aldworth

Objection reserved

803(6)

TX-171

Email chain on the March pricing dispute

Yes

Hollings

No objection

BW-601

Settlement note to the third supplier

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Withdrawn 14 Mar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Withdrawn after the meet and confer	17	4.1%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.

Two losses that are finished, and three wins that are not

The Motions in Limine, the Ruling Tracker, the Designation Index and Opposition Preparation.

Motion in Limine Template

MotionsRuling TrackerDesignationsOpposition

Motions

Thorncastle Instruments v. Bellweather Forge · prepared for the defence

Motions in Limine

One motion per way an exhibit fails, never one per exhibit, and every motion lists its numbers.

#	Relief sought	Ground	Ex.	How it was found
M-1	Exclude the exhibits never produced or disclosed	FRCP 37(c)(1)	22	Join: production log and disclosures
M-2	Exclude the exhibits with no custodian at all	FRE 901(a)	9	Join: both witness lists
M-3	Exclude ten more pending a named sponsor	FRE 901(a)	10	Join: both witness lists
M-4	Exclude the failure-rate summary chart	FRE 1006	4	Reading the documents
M-5	Exclude the post-recall redesign drawings	FRE 407	3	Reading the documents
M-6	Exclude evidence of the Verrick litigation	FRE 403	5	Reading the documents
M-7	Exclude references to liability insurance	FRE 411	2	Reading the documents
M-8 to M-11	Audit finding, complaint log, damages exhibits, late demonstratives	403, 802, 702	8	Reading the documents
Eleven motions, grouped by evidentiary basis	63	41 by join, 22 by reading

Relief sought

Ground

Ex.

How it was found

M-1

Exclude the exhibits never produced or disclosed

FRCP 37(c)(1)

Join: production log and disclosures

M-2

Exclude the exhibits with no custodian at all

FRE 901(a)

Join: both witness lists

M-3

Exclude ten more pending a named sponsor

FRE 901(a)

Join: both witness lists

M-4

Exclude the failure-rate summary chart

FRE 1006

Reading the documents

M-5

Exclude the post-recall redesign drawings

FRE 407

Reading the documents

M-6

Exclude evidence of the Verrick litigation

FRE 403

Reading the documents

M-7

Exclude references to liability insurance

FRE 411

Reading the documents

M-8 to M-11

Audit finding, complaint log, damages exhibits, late demonstratives

403, 802, 702

Reading the documents

Eleven motions, grouped by evidentiary basis

41 by join, 22 by reading

The two joins are 65.1 percent of the motion practice

M-1 through M-3 are 41 of the 63 exhibits, and not one of them is visible on the face of the document it concerns. A stock list of prejudice motions gets you M-6 and M-7.

Ruling Tracker

Two axes. The second one decides who has to say something at trial.

#	Ruling	Definitive?	Ex.	What trial still needs	Who
M-1	Granted	Definitive	22	Nothing
M-2	Granted	Definitive	9	Nothing
M-3	Granted	Subject to a sponsor	10	Object on authentication, ask to be heard	Second chair
M-4	Granted	Subject to the data	4	Object, Rule 1006, data never made available	Second chair
M-5	Granted	Impeachment only	3	Object in the case in chief, strike 118:4 to 119:22	Lead counsel
M-6	Granted	Definitive	5	Nothing
M-7	Granted	Definitive	2	Nothing
M-8	Denied	Definitive	3	Nothing. Preserved without renewing
M-9	Denied	Definitive	2	Nothing. Preserved without renewing
M-10	No ruling	Deferred	2	Object, Rule 702, renew the deferred motion	Lead counsel
M-11	No ruling	Deferred	1	Object, cite the date in the pretrial order	Second chair

Ruling

Definitive?

Ex.

What trial still needs

Who

M-1

Granted

Definitive

Nothing

M-2

Granted

Definitive

Nothing

M-3

Granted

Subject to a sponsor

Object on authentication, ask to be heard

Second chair

M-4

Granted

Subject to the data

Object, Rule 1006, data never made available

Second chair

M-5

Granted

Impeachment only

Object in the case in chief, strike 118:4 to 119:22

Lead counsel

M-6

Granted

Definitive

Nothing

M-7

Granted

Definitive

Nothing

M-8

Denied

Definitive

Nothing. Preserved without renewing

M-9

Denied

Definitive

Nothing. Preserved without renewing

M-10

No ruling

Deferred

Object, Rule 702, renew the deferred motion

Lead counsel

M-11

No ruling

Deferred

Object, cite the date in the pretrial order

Second chair

Two readings of the same afternoon

Read as	Result	Exhibits
Granted against denied	7 granted, 4 not	63 moved on
Definitive against provisional	6 finished, 5 live	43 done, 20 live

Read as

Result

Exhibits

Granted against denied

7 granted, 4 not

63 moved on

Definitive against provisional

6 finished, 5 live

43 done, 20 live

Both losses sit in the finished column and three of the wins do not. That is the whole reason this sheet sorts on the second row rather than the first.

Designations

Designation Index

The deposition designations joined back to the exhibits they discuss. 1,860 lines across nine witnesses.

Witness	Page and line	Lines	Exhibit	Exhibit status	Action required
R. Aldworth	118:4 to 119:22	44	TX-103	Excluded, M-5	Move to strike with the exhibit
P. Iyengar	55:1 to 56:9	34	TX-088	Excluded, M-2	Move to strike with the exhibit
V. Renner	88:2 to 89:6	30	TX-051	Excluded, M-1	Move to strike, keep our counter
T. Okonkwo	140:3 to 142:7	55	TX-224	Deferred, M-10	Object in the moment, renew M-10
D. Hollings	210:11 to 213:19	84	TX-219	Motion denied, M-8	Counter-designate and move on
K. Marsom	34:9 to 37:6	73	BW-508	No objection	None

Witness

Page and line

Lines

Exhibit

Exhibit status

Action required

R. Aldworth

118:4 to 119:22

TX-103

Excluded, M-5

Move to strike with the exhibit

P. Iyengar

55:1 to 56:9

TX-088

Excluded, M-2

Move to strike with the exhibit

V. Renner

88:2 to 89:6

TX-051

Excluded, M-1

Move to strike, keep our counter

T. Okonkwo

140:3 to 142:7

TX-224

Deferred, M-10

Object in the moment, renew M-10

D. Hollings

210:11 to 213:19

TX-219

Motion denied, M-8

Counter-designate and move on

K. Marsom

34:9 to 37:6

BW-508

No objection

None

108 lines that survive the exclusion order

Slice of the designated record	Lines	Witnesses	Share
Everything designated, both sides	1,860	9	100%
Discussing an exhibit under motion	247	5	13.3%
Discussing an exhibit actually excluded	108	3	5.8%

The exhibit is out and the testimony reading it to the jury is still in. The register cannot see that, because it has no idea what the transcripts say.

Opposition

Their four motions, answered exhibit by exhibit

Opposition Preparation

Same discipline as ours. A weak position is marked weak rather than argued at the volume of a strong one.

#	What they move on	Ours	What we show	Strength
M-A	Certified material test reports, hearsay and lab bias	BW-508 to BW-516	Marsom lays the records foundation for all nine, and the lab was retained before the dispute arose	Strong
M-B	Incoming inspection log, hearsay within a business record	BW-533	The inner layer is their own employee speaking, and Okonkwo lays the outer one	Strong
M-C	Third-supplier correspondence, compromise negotiations	BW-601, BW-602	Nothing. The objection is right and both went out with 15 others on 14 March	None
M-D	Cost-of-cover summary, invoices produced late	BW-644	Produced 3 April with a cover letter, seven weeks before fact discovery closed	Strong

What they move on

Ours

What we show

Strength

M-A

Certified material test reports, hearsay and lab bias

BW-508 to BW-516

Marsom lays the records foundation for all nine, and the lab was retained before the dispute arose

Strong

M-B

Incoming inspection log, hearsay within a business record

BW-533

The inner layer is their own employee speaking, and Okonkwo lays the outer one

Strong

M-C

Third-supplier correspondence, compromise negotiations

BW-601, BW-602

Nothing. The objection is right and both went out with 15 others on 14 March

None

M-D

Cost-of-cover summary, invoices produced late

BW-644

Produced 3 April with a cover letter, seven weeks before fact discovery closed

Strong

What goes in every one of them

The exhibit numbers they did not identify. Half of these motions describe a category, and naming the exhibits inside it is the first paragraph, because it converts their motion into something a court can rule on.

Then one sentence on what we will not oppose, and a request for a definitive ruling in those words. Conceding the two exhibits that should not be on our list buys credibility on the seven that should.

Edit with AI

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.

Sources

Written by

Chandler Supple

Co-founder & CEO, River

Chandler has spent the last six years working in AI, building tools for millions of users and Fortune 100 companies. In 2025, he co-founded River to build a new kind of operating system for AI agents.

LinkedIn GitHub X

Reviewed by

Brian Joseff, Co-founder, River

LinkedIn X

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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

Motion in Limine Template

Every number on the joint list, and the answer next to it

The three middle columns are the ones nobody else has

Two losses that are finished, and three wins that are not

Motions in Limine

The two joins are 65.1 percent of the motion practice

Ruling Tracker

Two readings of the same afternoon

Designation Index

108 lines that survive the exclusion order

Opposition Preparation

What goes in every one of them

What's in the pack

Exhibit Register

Designation Index

Ruling Tracker

Motions in Limine

Opposition Preparation

Offers of Proof and Trial Objections

What a Ruling Actually Preserves

How to use it

Open in River, or take it blank

Every exhibit, then the joins

Group by how the exhibit fails

Record the ruling on two axes

Frequently asked questions

Is this template free?

What format are the downloaded files?

One omnibus motion, or a separate motion for each issue?

How does it decide which exhibits need a motion?

Does a granted motion in limine settle the issue?

Do the deposition designations need their own motions?

What does Edit with AI actually do?

Sources

Chandler Supple

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More free templates

Start from the exhibit list, not from a list of motions