Fill and Sign the Plaintiffs Opposition to Defendants Motion in Limine to Form

- 1 - IN THE CIRCUIT COURT OF ______________, ___________________________ PLAINTIFFS, V. NO. DEFENDANT ) )))))))) MOTION IN LIMINE COME NOW the Plaintiffs, _____________________________, through counsel, and move the Court for an Order commanding and directing that Defendant, Defendant's witnesses, Defendant's attorney, and Defendant's representatives refrain from mentioning, alluding to, telling, describing or communicating in the presence of the jury that hears this case any of the following facts and matters for the reasons stated below: 1. Any testimony regarding Plaintiff's not wearing seat belts at the time of the accident on _________, 20____, as it is not relevant and _____________ Code __________ (_____) provides that failure to provide or use a seat belt restraint device or system shall not be considered contributory or comparative negligence. 2. Such evidence serves no purpose other that to appeal to the bias, prejudice and passion of the jury. 3. The Plaintiff is entitled to this case being tried without the interjection of the matters described above, and Plaintiff is best protected by an Order of the Court in advance of trial so that interruptions of testimony with objections is unnecessary and so that Plaintiff can have a fair trial. WHEREFORE, PREMISES CONSIDERED, Plaintiff moves this Court to enter an Order as requested. - 2 - Respectfully submitted, ____________________________ ATTORNEY FOR PLAINTIFFCERTIFICATE OF SERVICE I, ____________________________, do hereby certify that I have this day mailed, via United States Mail, postage prepaid, a true and correct copy of the above and foregoing Motion In Limine to: _____________________________________________ THIS the _______ day of _________ 20______.