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§ 12:17 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 existence or non-
existence of coverage based on the fact that [name of moving party/insured] is pursuing a
claim on a lost policy. The motion is based upon the grounds that there is no genuine
dispute as to the material terms of the policy, and the evidence is irrelevant to the issues in
this case and will create a substantial danger of undue prejudice to [name of moving