The purpose of a motion in limine is to obrain a court order:
1.To preclude the opposing party from introducing certain prejudicial evidence.
2.To instruct opposing counsel, and any person in opposing counsel’s control, to avoid any mention of certain evidence or testimony during trial or in argument in front of the jury.
You should have a pretty good idea as the what MILs you want to file and serve based on the discovery conducted to that point. You should know primarily what exhibits and witnesses the opposing party is likely to introduce. Go ahead and file the MILs with the inormation you have. To the extent you are unable to cover a subject due to ongoing discovery (e.g., expert depositions that have not yet taken place), you can do an MIL based on anticipated testimony of the expert. ALternatively, the court likely will be understanding of your situation and likely will grant leave to submit a late MIL for good cause. Good luck.
This response is for information purpose only and does not constitute a legal advice. This response does not create an attorney-client relationship.
Have you prepared and responded to discovery? Are there certain facts and testimony that you don't want included in evidence? Those are some suggestions. It's true that CRC does say that although you can certainly include motions in limine at the time of trial. I would suggest that you speak with a trial lawyer who knows how to handle courtwork.
You didn't state what kind of case this is so I couldn't really comment any further.