Offensive Use of Motions in Limine

We recently handled a civil matter in which our client was alleged to have mistreated his former spouse. During the investigation of the spouse's case, we discovered that the spouse had made similar claims of mistreatment during her divorce proceeding against her first husband. Moreover, we discovered that the spouse had been convicted of criminal contempt during those proceedings, and that the court had sentenced her to jail for a period of 48 hours. The court based its findings on false testimony provided by the spouse and the spouse's solicitation of a third party to commit perjury. Given the great impeachment value of the spouse's prior conviction, as well as the similarity between the matter in which she perjured herself and the case we were defending, we were excited to have this evidence and wanted to use it if the case was ever tried.

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