draft a motion in limine using the laws of your state.

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Your supervising attorney is preparing for a trial. The Plaintiff in
this case, Billy Bob, began his employment with Widget World Co., the
Defendant, on January 2, 1990. Mr. Bob worked as a truck driver for
Widget World, initially in its Blackacre terminal, and then in its
Whiteacre terminal. Widget World is a widget company that utilizes
hazardous materials on a daily basis. On November 11, 20015, Mr. Bob was

In September of 2015, Mr. Bob and several other Widget World
employees were sent to Whiteacre to refurbish a floor in the plant with
epoxy product. There is a question as to whether Mr. Bob followed
instructions in refurbishing the floor in the plant.

Thereafter, on November 9, 2015, Mr. Bob suffered from a workplace
injury, and reported it to the company. Mr. Bob has had on-going
rheumatoid arthritis, and in October of 2015, he stepped off the back
end of a trailer and jarred himself when he hit the ground. A few weeks
later he felt such a sharp pain from his injury that he could hardly
walk. His pain was so intense that he was taken to the local emergency room and received several painkiller injections. He
informed the company that he was going to file a worker’s compensation
claim pertaining to that injury. When Mr. Bob informed Mr. Widgetall,
Widget World’s Safety Director, about his intention, the conversation
between the two became heated.

At a meeting on November 11, 2015, Mr. Bob reiterated his intention
to file a worker’s compensation claim for his injury. Mr. Mitchell, the
safety director for Roeder, then produced a termination letter to Mr.
Bob, alleging insubordination and terminated Bob’s employment. The next
day, Mr. Bob filed a workers’ compensation claim.

Mr. Bob initiated this case, alleging that he was terminated in
relation for his intent to file a workers’ compensation claim, in
violation of Whiteacre law. Widget World has filed a counterclaim
against Mr. Bob, alleging defamation. The trial is set to commence in
two weeks, and motions in limine are required to be filed this week.
Suzy Cue is your supervising attorney at Alpha & Beta LLC, 432 Brown
Ct, Whiteacre. She would like you to prepare a motion in limine to keep
any mention of the following evidence out of court:

  • Any mention of Billy’s psychological counseling, which he has been receiving for the last 5 years
  • Any mention of Billy’s previous conviction for possession of marijuana
  • Billy’s request for $50,000 in exchange for his dismissal of the case

Using this sample provided by Suzy, as well as your own research, draft a motion
in limine using the laws of your state.


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