§ 12:52 Suggested motion text

“[Name of moving party/insurer] hereby moves this Court for an order excluding any and
all evidence, references to evidence, testimony or argument relating to other claims or
lawsuits against [name of moving party/insurer] or any of its affiliates or subsidiaries. The
motion is based upon the grounds that the evidence is irrelevant to the issues in this case in
that the mere existence of other lawsuits against [name of insurer] has no relevance to the
specific issues presented in this case. Introduction of such evidence will create a substantial
danger of undue prejudice to [name of moving party/insurer].”