Write a Motion to Strike on the Billy Bob case. the Plaintiff in this case, Billy Bob worked for Widget World Co., the Defendant, as a truck driver. Mr. Bob suffered from a workplace injury, and reported it to the company. Mr. Bob has had on-going rheumatoid arthritis, and in October of 2015, he stepped off the back end of a trailer and jarred himself when he hit the ground. A few weeks later, he felt such a sharp pain from his injury that he could hardly walk. His pain was so intense that he was taken to the local emergency room and received several painkiller injections. He informed the company that he was going to file a worker's compensation claim pertaining to that injury. When Mr. Bob informed Mr. Widgetall, Widget World's Safety Director, about his intention, the conversation between the two became heated. Mr. Mitchell, the safety director for Widget World, then produced a termination letter to Mr. Bob, alleging insubordination, and terminated Bob's employment. The next day, Mr. Bob filed a workers' compensation claim. Mr. Bob initiated this case, alleging that he was terminated in relation for his intent to file a workers' compensation claim, in violation of Whiteacre law.

The trial is set to commence in two weeks, and motions in limine are required to be filed this week. Mr. Smith would like you to prepare a motion in limine to keep any mention of the following evidence out of court:

• Any mention of Billy's previous conviction for possession of marijuana. Billy has used recreational marijuana in the past. It was never while working, he was never drug tested, and it had no impact on his performance. However, the Defendant may try to raise this issue. (You will need to fill in the facts in the section provided).
• Billy's request for $50,000 in exchange for his dismissal of the case. The Defendant has been repeatedly mentioning that the case is only worth $50,000, since Billy requested that amount in settlement talks. However, Billy would like to ask a jury for substantially more money. (You will need to research and then fill in the section of the Federal Rules of Evidence that prohibit settlement discussions from being discussed at trial).

Use this draft:

IN THE DISTRICT COURT

TEXARKANA

BILLY BOB Plaintiff v. WIDGET WORLD CO. Defendant	* * * * * * * * *	Case No.: 19-2522 Before the Honorable Judge Pollex PLAINTIFF'S MOTION IN LIMINE Joe Doe 585 Main St Texarkana, 45854 Telephone: (485)879-5555 Attorney for Plaintiff
* * * * * * * * *

Plaintiff Billy Bob ("Bob"), by and through counsel, submits the following motion in limine and supporting legal memoranda.

I. PREVIOUS CRIMINAL HISTORY

Plaintiff moves this Court to exclude any evidence of <>, as it is not relevant and should not be permitted in the event Defendant attempts to use it to impeach Plaintiff's character. FRE 404(b)provides "evidence of a crime, wrong, or other act is not admissible to prove a person's character in order to show that on a particular occasion the person acted in accordance with the character." Furthermore, FRE 609(b) states that evidence of a conviction or prior crime should be excluded "if more than 10 years have passed since the witness's conviction or release from confinement for it, whichever is later. Evidence of the conviction is admissible only if: (1) its probative value, supported by specific facts and circumstances, substantially outweighs its prejudicial effect; and (2) the proponent gives an adverse party reasonable written notice of the intent to use it so that the party has a fair opportunity to contest its use."

In this case, Plaintiff testified >Furthermore, there is no probative value to introducing this information, and Defendant has not provided notice of its intent to introduce such information, either written or otherwise. Therefore, under FRE 404(b) and FRE 609(b), Plaintiff's prior criminal record is inadmissible and irrelevant. Accordingly, Plaintiff respectfully requests that this Honorable Court exclude any evidence that Defendant may attempt to introduce regarding Plaintiff's criminal history, or any references to his criminal history.

II. SETTLEMENT DISCUSSIONS

Plaintiff also moves this Court to exclude any evidence of settlement discussions in this matter. Defendant may attempt to introduce Plaintiff's request from settlement discussions. In an effort to encourage frank settlement negotiations, Rule <> of the Federal Rules of Evidence prohibits the use settlement offers or statements made in furtherance of negotiating settlements to prove liability, validity of, or the amount of a claim that is in dispute, or to impeach by using statements made in settlement negotiations as prior inconsistent statements. As such, no mention of the settlement discussions should be made.

Plaintiff therefore, requests this Honorable Court exclude any evidence that Defendant may attempt to introduce regarding Plaintiff's criminal history, or any references to settlement discussions between the parties.

Respectfully submitted,

/s/ Joe Doe__________________

Joe Doe

585 Main St

Texarkana, 45854

Telephone: (485)879-5555

Attorney for Defendant

NOTICE OF SERVICE

I hereby certify that a copy of the foregoing was filed electronically. Notice of this filing was sent to all parties by operation of the Court's electronic filing system. Parties may access the filing through the Court's system.

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