Motion in Limine Issue List
In the run-up to trial, once exhibit and witness lists are exchanged, to make sure no excludable or pre-admissible evidence is missed before the motion in limine deadline.
Motions in limine shape what the jury hears. Missing an issue can mean an insurance reference, an undisclosed expert opinion or a prior incident comes in front of the jury, and an objection at trial cannot un-ring that bell. With two exhibit lists, two witness lists, expert disclosures and a pretrial order to cross-check, the risk is less about legal analysis than about something slipping through.
This prompt gives Claude the case summary, both sides' exhibit and witness lists, and any other pretrial materials, then asks for an issue list rather than drafted motions. Claude reviews for common categories, including prior bad acts, subsequent remedial measures, insurance, settlement communications, late experts and hearsay, and returns a ranked table quoting the list entry behind each issue, the ruling to seek, the basis as a bracketed evidence-rule placeholder, the likely response and a strength rating. It also anticipates motions against your evidence and identifies items better left for trial objections.
Which motions to file, and how to frame them for your judge, are strategic decisions that stay with you. Claude is told not to cite cases or rule numbers, so every basis must be confirmed against the evidence rules that govern your court and supported with authority you have verified. Exhibit descriptions can mislead, so review the underlying exhibits before relying on any flagged issue.
The Prompt
I represent [PARTY ROLE], [CLIENT NAME], in [CASE NAME], a [CASE TYPE] case set for [JURY/BENCH] trial in [COURT] on [DATE]. Motions in limine are due [DATE]. I want an issue list, not drafted motions. <case_summary> [CLAIMS, DEFENSES AND OUR THEORY OF THE CASE] </case_summary> <exhibit_lists> [PASTE BOTH SIDES' EXHIBIT LISTS] </exhibit_lists> <witness_lists> [PASTE BOTH SIDES' WITNESS LISTS, INCLUDING EXPERT DISCLOSURES] </witness_lists> <other_materials> [OPTIONAL: PRETRIAL ORDER, KEY DEPOSITION EXCERPTS, PRIOR RULINGS] </other_materials> Review the materials for evidence we should seek to exclude, limit or pre-admit. Consider categories such as prior bad acts or other claims, subsequent remedial measures, references to insurance, settlement communications, undisclosed or late-disclosed experts and opinions, lay opinion, hearsay and hearsay within hearsay, character evidence, unfair prejudice, and anything we want ruled admissible in advance. Output a ranked table: Priority (1 = most important) | Issue | Exhibit or witness (quote the list entry) | Ruling we want (exclude, limit, pre-admit) | Basis as [EVIDENCE RULE: short description], or [APPLICABLE RULE: short description] for procedural issues such as late disclosure | Likely opposing response | Strength (strong, arguable, weak) | Facts or materials still needed. Then give: - Issues the other side is likely to raise against our evidence, with our likely response. - Items better handled by objection at trial than by motion, and why. Do not cite cases or rule numbers; I will supply authority. Quote the list entry or document behind every issue, and flag anything you inferred from a description alone. This is a draft for attorney review.
Example Output
A priority-ranked table of evidentiary issues with the list entry quoted, the ruling sought, a bracketed evidence-rule basis, the likely response and strength, plus issues the other side may raise and items to save for trial objections.
Illustrative example — names, figures, and facts are fictional.
MOTION IN LIMINE ISSUE LIST: Brandt v. Orchard Valley Equipment Co. (fictional)
Plaintiff-side | Jury trial | Product liability (ladder collapse)
1 | Late expert opinion on user error | Def. witness list: "Dr. K. Sorensen, human factors" | Exclude, or limit to disclosed opinions | [APPLICABLE RULE: expert disclosure and exclusion of undisclosed opinions] | Defendant may say the opinion was in the supplemental report | Strong if no supplement was served | Confirm the service date of any supplement.
2 | Plaintiff's 2018 workers' compensation claim | Def. Ex. 44: "Claim file, Brandt, 2018" | Exclude | [EVIDENCE RULE: relevance and unfair prejudice; character evidence] | Defendant will tie it to a prior back injury | Arguable | Medical records needed to show the 2018 injury is unrelated (knee vs. back).
3 | Health-plan payments toward Plaintiff's medical bills | Def. Ex. 52: "Health plan payment ledger" | Exclude | [APPLICABLE LAW: collateral source rule] and [EVIDENCE RULE: unfair prejudice] | Defendant may argue it bears on the reasonable value of medical expenses | Arguable; the rule varies widely by jurisdiction | Confirm [JURISDICTION]'s collateral source rule and any statutory changes.
4 | Pre-admit the warning label comparison chart | Pl. Ex. 12 | Pre-admit | [EVIDENCE RULE: summaries of voluminous records] | Foundation objection | Arguable | Underlying labels must be produced and available.
LIKELY DEFENSE MOTIONS
- To exclude Pl. Ex. 27 ("2025 Engineering Change Notice, hinge rev. C") as a subsequent remedial measure. Our response: offered only for feasibility if Defendant disputes it, or for impeachment; Answer ¶ 22 is unclear on feasibility, so confirm before relying on that exception.
- To exclude Pl. Ex. 19 (other incident reports). Our response: substantial similarity; need details for each incident.
BETTER AS TRIAL OBJECTIONS
- Lay opinion from the store clerk on ladder condition: depends on foundation at trial.
FLAGGED: Issue 4 inferred from the exhibit description only.
All names and facts are fictional and illustrative.Tips
- •Paste the other side's expert disclosures in full; late or undisclosed opinions are among the most valuable issues to catch.
- •Exhibit descriptions are often vague. Where Claude flags an issue 'inferred from a description alone,' pull the actual exhibit before you decide.
- •Replace each [EVIDENCE RULE] and [APPLICABLE RULE] placeholder with the governing rule in your court (for example, the federal or state counterpart on subsequent remedial measures) and verify it.
- •Check the judge's standing order on motions in limine; many limit their number or require a meet-and-confer first.
- •The list is a draft for attorney review; verify all authority before briefing.
Frequently Asked Questions
Why does the prompt avoid citing rule numbers?
Because the governing evidence rules depend on your court. Federal courts apply the Federal Rules of Evidence, and states have their own codes with different numbering and sometimes different substance. Bracketed placeholders keep the issue list accurate across jurisdictions and make sure you supply and verify the rule and authority that actually apply.
Can Claude draft the motions themselves?
It can help, but start with the issue list. Once you have chosen which issues to pursue and confirmed the authority, use the motion brief outliner to structure each motion, giving Claude the verified rule text and cases you plan to rely on. Drafting before you have chosen the issues tends to waste effort on weak motions.
What if the exhibit list only has vague descriptions?
That is common, and it is why the prompt asks Claude to flag issues inferred from a description alone. Treat those flags as a document request to yourself: pull the exhibit and check whether the issue is real. If the descriptions are too vague to evaluate, that may itself be worth raising under the pretrial order.
Does this help defense counsel too?
Yes. Set the party role to defendant and the same review applies. Defense counsel often focus on prior claims, medical history, damages evidence and expert scope, while plaintiffs often focus on remedial measures and late disclosures. The anticipated-motions section is useful on either side for preparing responses in advance.
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