West Palm Beach car accident Plaintiff ’s Motion In Limine (Motor Vehicle Collision)

West Palm Beach car accident Plaintiff ’s Motion In Limine (Motor Vehicle Collision)
In the _______ Court of ____________ County, _________
)
____________, West Palm Beach car accident Plaintiff )
)
vs. ) Case No. _____________
)
____________, Defendant )
WEST PALM BEACH CAR ACCIDENT PLAINTIFF ’S MOTION IN LIMINE
Comes now the West Palm Beach car accident Plaintiff , by and through his attorney of record, and moves the court for an Order in Limine to prohibit defendants and their counsel, or any of their witnesses, from mentioning or asking questions, either directly or indirectly, before the jury or within the hearing of the jury, without prior approval of this court, the following matters:
1. When the West Palm Beach car accident Plaintiff first consulted with counsel, or when suit was filed, or the reasons why suit has been filed.
2. That any judgment rendered in this case might adversely affect the members of the jury, or raise their insurance costs, or any other reference appealing to the self-interests of the jury.
3. Any adverse comment upon West Palm Beach car accident Plaintiff ’s failure to call each and every treating physician.
4. Whether any or all of West Palm Beach car accident Plaintiff ’s medical expenses have been paid, or not paid, or are not fully paid.
5. Any mention of or adverse comment upon West Palm Beach car accident Plaintiff not calling any one or more experts designated by him in his answers to interrogatories.
6. The report of Dr. Edward Prose.
7. That the examination or report or work performed by Dr. Edward Prose in this case constitute an “Independent Medical Exam:”
8. To prevent the witnesses Dr. Edward Prose and Roland Kruse from testifying to facts or opinions which are not disclosed in their depositions.
9. To prevent witness Roland Kruse from testifying that anyone driving on Highway 71 on November 20, 2003 with their headlights on could see a “sea of reflective lights” or any reflective capability of the glass beads at the intersection of business 71 and U.S. 71 on November 20, 2003.
10. To prohibit witness Roland Kruse from testifying that defendant Parmenter has medical and emotional problems associated with the accident that affect his ability to testify about the facts of the automobile wreck.
11. That West Palm Beach car accident Plaintiff has a pre-existing condition of diabetes or a history of heart disease.
12. To prohibit introduction of the statement made in Reginald Brown’s records and/or clinic notes attributed to West Palm Beach car accident Plaintiff that “I’m not going to the f****** hospital to spend $1200.00 to ride in the f****** ambulance” or the statement from Mr. Fackler’s emergency room medical records that he was a “restrained driver, high speed mva.”
13. To prohibit Missouri Highway Patrol Corporal Michael Foster from testifying about any contributing circumstances with respect to any driver in this automobile wreck as a result of his investigaion.
14. To prohibit Corporal Michael Foster from testifying as to any conversations he had with West Palm Beach car accident Plaintiff after the wreck about Corporal Foster’s conclusions as to “contributing circumstances.”
15. To prohibit Corporal Michael Foster from testifying as to any conversations he had with Joleen Ambruster.
16. To prohibit defendant Parmenter from testifying that Corporal Michael Foster was of the opinion that he (Parmenter) was not at fault in the accident.
17. To prohibit Corporal Michael Foster from testifying as to when the 45 mile per hour speed signs were removed from the area of the automobile wreck.
18. To prohibit defendant Robert Dunkirk from testifying regarding any of the conversations of the highway patrol officers at the scene of the collision immediately after their arrival.
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Attorneys for West Palm Beach car accident Plaintiff

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