§ 12:41 Suggested motion text

“[Name of moving party] hereby moves this Court for an order excluding any and all evidence, references to evidence, testimony or argument relating to [identify the improper evidence to be excluded, e.g. cross-complaint, appeal, etc.] to prove bad faith. The motion is based upon the grounds that the evidence is irrelevant to the issues in this case, and will create a substantial danger of undue prejudice to [name of moving party].”

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