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Let's start with a motion in limine included in virtually every set defense attorneys in Georgia file: a prohibition on so-called Golden Rule arguments, in which a trial attorney asks the jury to place themselves in the plaintiff's shoes.
A "motion in limine" is a pretrial motion that seeks the exclusion of specific evidence or arguments from being presented during a trial. A motion in limine is decided by the judge outside of the presence of the jury.
Motions in Limine must be filed and heard no later than three weeks prior to trial. Motions are heard on Mondays at a.m. Failure to comply constitutes a waiver. Requested Voir Dire, Verdict Form and Jury Instructions must be provided to the law clerk at least two days prior to trial.
The golden rule arises out of two fundamental principles: that courts must interpret statute "ing to the intent of them that made it", and that "the words of the statute speak the intention of the Legislature".
Rule 2.309 - Interrogatories to Parties (A) Availability; Procedure for Service; Limits. (1) A party may serve on another party written interrogatories to be answered by the party served or, if the party served is a public or private corporation, partnership, association, or governmental agency, by an officer or agent.
No later than 20 days before trial, each party must file all motions in limine and must lodge with the court any items served under (b)(2)-(9) and (c).
The most common use of the in limine motion is to exclude irrelevant and/or prejudicial evidence.
Golden rule argument is an argument made by a lawyer during a jury trial to ask the jurors to put themselves in the place of the victim or the injured person and deliver the verdict that they would wish to receive if they were in that person's position.