P. 1
§ 12:61 Suggested Motion Text

§ 12:61 Suggested Motion Text

|Views: 3|Likes:
Published by justicefornyefrank

More info:

Published by: justicefornyefrank on Dec 18, 2009
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as RTF, PDF, TXT or read online from Scribd
See more
See less

05/11/2014

pdf

text

original

§ 12:61 Suggested motion text

“[Name of moving party] hereby moves this Court for an order determining [insert issue that is question of law, e.g., interpretation of policy terms; issue of equitable estoppel; insurer's duty to defend; etc.] and excluding any and all evidence, testimony or argument pertaining to [insert issue that is question of law, e.g., interpretation of policy terms; issue of equitable estoppel; insurer's duty to defend; etc.]. The motion is based upon the grounds that such evidence is improper and inadmissible and would therefore create a substantial danger of unfair prejudice to the moving party.”

You're Reading a Free Preview

Download
scribd
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->