West Palm Beach car accident Plaintiff ’s Motion in Limine
In the __________ Court of ___________ County, ____________

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_______________, West Palm Beach car accident Plaintiff )
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vs. ) Case No. __________
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_______________, Defendant )
WEST PALM BEACH CAR ACCIDENT PLAINTIFF ’S MOTION IN LIMINE
COMES NOW the West Palm Beach car accident Plaintiff , by and through his attorneys of record, and move the court for an Order In Limine to prohibit defendant, and its counsel, or any of its witnesses from mentioning or asking questions, either directly or indirectly, before the jury or within the hearing of the jury, without the prior approval of this court, the following matters:
1. Testimony relating to general industry practice at the time of manufacture of the gas grill in question in 1993 with respect to the placement of the two safety mechanisms in question on propane gas grills.
2. The fact that the Model Number ____ _________ Gas Grill involved in this case was manufactured in accordance with or complied with various voluntary industry standards including, but not limited to, ANSI Standards.
3. Any testimony relating to industry standards including ANSI Standards applicable to gas barbeque grills such as the one involved in this case or the modification or change of those standards or the participation by the defendant in those changes or the purpose or reason that defendant participated in the changing of those standards.
4. Testimony as to reasons the defendant did not employ the two safety devices on its product in 1993 or as to the reasonableness of the defendant’s actions in not equipping its gas grills with the safety devices until 1995.
5. The introduction of “state of the art” evidence as defined by Section 537.764 R.S.Mo, 1994, as amended.
6. The fact that the West Palm Beach car accident Plaintiff had insurance with ________________ Insurance Company or that __________________ Insurance Company has a subrogation interest in this litigation.
7. The fact West Palm Beach car accident Plaintiff has stricken various counts and allegations from his petition or dismissed without prejudice various counts of his petition.
8. Testimony by defendant’s expert witness, _________________, that the gas grill burner was operating, just prior to the time of the fire, in a manner different than that testified to by the three eyewitnesses to support his opinion that there was a blockage or obstruction of the venturi tube of the gas grill prior to the fire in question.
9. Evidence or testimony by defendant’s expert witness, _______________, that the West Palm Beach car accident Plaintiff was contributorily at fault because he violated the instruction in the instruction manual by not cleaning the venturi tubes of the grill after the grill was initially ignited on the day of the fire.
10. Evidence or testimony by defendant’s expert witness, _______________, that the West Palm Beach car accident Plaintiff was contributorily at fault because he violated the portion of the instruction manual for the gas grill relating to “Grill shall not be located under unprotected overhead (enclosed carport, garage, porch, patio) made of combustible construction,” “Grill is for outdoor use only,” or “Never operate in enclosed space, garage, or building.”
11. That West Palm Beach car accident Plaintiff was in any way negligent or at fault or contributed to his damages in this case.
12. Evidence regarding possible causes of the fire to which neither of defendant’s experts can testify to a reasonable degree of engineering certainty that any of the so called possibilities occurred.

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Attorneys for West Palm Beach car accident Plaintiff