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§ 12:9 Suggested motion text

“[Name of moving party/insured] hereby moves this Court for an order excluding any and
all evidence, references to evidence, testimony or argument relating to the meaning of
[include policy provision at issue] in the insurance policy upon which [name of moving
party/insured]'s claim is based. The motion is based upon the grounds that the evidence is
irrelevant to the issues in this case, absent a preliminary showing of ambiguity, will confuse
the jury, and will create a substantial danger of undue prejudice to [name of moving
party/insured].”

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