Fill and Sign the Comes Now Plaintiff by and through Hisher Attorney of Record with This Hisher Form

IN THE CIRCUIT COURT OF COUNTY, MISSISSIPPI PLAINTIFFVS.DOCKET NO. DEFENDANT MOTION IN LIMINE COMES NOW plaintiff by and through his/her attorney of record with this his/her motion as follows:1.This civil action is set for trial , 20 .2.Plaintiff's cause of action is, in part, for non-payment of credit life insurance benefits under policy # issued by to on , 20 .3.The defendant insurance company issued a letter of denial dated , 20 wherein it stated its reason for refusing to pay credit life death benefits under the policy. A copy of said letter of denial of the claim is attached hereto and is plaintiff's pre-marked Trial Exhibit # P-ll.4.Plaintiff respectfully submits that the defense of should be limited at trial to the reason for denial of the subject claim as given , and pursuant to Bankers Life vs. Crenshaw, 483 So.2d 254 (Miss. 1985), citing Aetna Life & Casualty Co. Inc. vs. Lavoie, 505 So.2d 1050 (Ala. 985) (the issue is not the defense which Bankers Life at trial finally settled upon to defend the suit, but the reason it gave Crenshaw for denying the claim.) WHEREFORE, PREMISES CONSIDERED, plaintiff respectfully submits that this Court issue an order directing that the defense of in the trial of this cause for non-payment of the claim for credit life benefits be limited to the defense for non-payment given in their letter of denial dated , 20 . Respectfully submitted,_______________________________________ Attorney for Of Counsel: Telephone: MSB # Attorney for NOTICE OF MOTION TO: PLEASE TAKE NOTICE that undersigned counsel will call up and request that Plaintiff's motion in limine in the above-styled and numbered matter be heard before the Honorable , at the County Circuit Courthouse in , Mississippi, at : a.m./p.m. on , , 20 , or as soon as counsel can be heard.This, the day of 20 .