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Motions in Limine: An Update on Uses, Abuses, and Pitfalls

Motions in limine (“on or at the threshold” or “in the beginning”) can be a useful tool in a trial lawyer’s hands. Used strategically and prophylactically, they can “eliminate the noise surrounding” a trial by preventing an...more

When Is a Defense “Available”? Avoiding Waiver by Being Bold When Asserting Defenses

It is well known that, at least in the federal system and Florida, a defendant who fails to raise lack of personal jurisdiction in a pre-answer motion to dismiss waives that defense. But there is an exception to this rule: If...more

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