![]() “Don’t re-invent the wheel” is the first principle here. Chances are, if you haven’t done this before, somebody else at your firm has. Because the range of some people’s obtusity (is that even a word?) is seemingly endless, every mass tort will present at least some new or different motion in limine possibilities.īut the key to selecting motions in limine is the same as much of the rest of the process – on the whole, motion in limine practice isn’t plowing new ground. ![]() It seems, though, that every company has a couple of people who don’t quite grasp that snarky things put in emails, or making off-the-wall marketing proposals – even if nothing comes of them – can come back to bite the company itself in litigation. Obviously, that varies with the litigation. Select – We don’t presume to tell anybody all the motions in limine to file in any particular mass tort. ![]() So today we’re going to discuss some dos – and some don’ts – of drafting motions in limine, with an emphasis (duh!) on mass pharmaceutical/medical device torts. In the spirit of “there but for the grace of God, go I,” he has expressed empathetic frustration. The other half has been there and done that. ![]() One of the blogging duo is currently involved in one of the more headache-inducing aspects of mass tort litigation, the process of putting together motions in limine. This is a practical – some would say, impractical – post. ![]()
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