If You Can't Explain Your In Limine Motion Simply, It is Not Likely to Be Granted.

Here's an interesting standard Judge King lays out for an in limine motion -- if you can't explain it simply to the Court pretrial, it's not something the Court should be ruling on pretrial:

In limine consideration of arguments and evidence relating to the Defendants' "strategic planning and strategic planning documents'' is equally misplaced. One need look no further than Defendants' memorandum (pp. 6-10 - D.E. #84) to quickly discern that the complexities of even describing this issue to the Court pretrial renders it not a matter which should be considered in limine. Experienced trial counsel, and certainly the Court, can envision perhaps a half a dozen ways in which these matters might be relevant during the trial presentation of evidence. Counsel will have the full opportunity to make whatever objection they wish to make - materiality, relevancy, work product, etc. - if, and when, the evidence is sought to be presented.

Simplify, simplify, simplify!