When writing a written motion in limine to include rather than preclude certain evidence, what do you put on your Notice of Motion page? CPLR Art. 45 is for evidence, but it's all about excluding; is there anything I can write in which I say "this material should be admitted"? I considered 3101: "There shall be full disclosure of all matter material and necessary in the prosecution or defense of an action, regardless of the burden of proof." But that's only for what is discoverable, not what's admissible. Anything else I should consider? Cite a case instead maybe? Thank you, Michael S. Leinoff, Esq. Lebedin Kofman, LLP 300 Merrick Road, Suite 403 Lynbrook, NY 11563 <mailto:mleinoff@lebedinkofmanlaw.com> mleinoff@lebedinkofmanlaw.com Phone: (212) 500 - 3273 ext. 103 Fax: (855) 696 - 6848 NYC Offices at: 26 Broadway, 3rd Floor New York, NY 10004 <http://www.lebedinkofman.com/> www.lebedinkofman.com <http://www.nycdebtlawyers.com/> www.nycdebtlawyers.com _____ Please note that the use of the internet for communications with the firm will not establish an attorney-client relationship, and messages containing confidential or time-sensitive information should not be sent via this media. CONFIDENTIALITY NOTICE TO RECIPIENT(S): This e-mail transmission (and/or the attachment(s) accompanying it) may contain confidential information, belonging to the sender, which is protected by the attorney-client privilege. The information is only for the use of the intended recipient. If you are not the intended recipient, you are hereby notified that any disclosure, copying or distribution of any information in this transmission, or the taking of any action in reliance on the contents of this transmission, is strictly prohibited. Any unauthorized interception of this transmission is illegal under the law. If you have received this transmission in error, please promptly notify the sender by reply e-mail, and then destroy all copies of this transmission. Thank you. CAUTIONARY NOTICE TO AUTHORIZED RECIPIENT(S): Unless the recipient(s) and the law firm transmitting this message are parties to a signed retainer agreement binding the law firm to act as attorney for the recipient(s), neither this law firm nor any attorney in its employ is (or may be deemed to be) acting as such attorney. Any message or data sent to any recipient(s) as a courtesy is without the benefit of any actual knowledge about the particular situation of such recipient(s) and is without any "due diligence" or similar inquiry on the part of this firm. Everything stated is purely a general comment or suggestion based upon the limited facts presented to this firm. The comments in this e-mail transmission (and/or the attachment(s) accompanying it) are free and intended to be educational, but are NOT intended to be relied upon by any recipient(s) as legal advice or counsel rendered to or for the benefit of the recipient(s). Each recipient should engage the services of, and thereafter consult with, his or her own qualified attorney who is familiar with the local rules of court and the applicable laws of the governing jurisdiction with regard to the specific circumstances. Lebedin Kofman LLP is a debt relief agency helping people to file for bankruptcy relief under the bankruptcy code. -- This email has been checked for viruses by AVG antivirus software. www.avg.com