[brief] The parties filed several pre-trial motions in limine addressing a variety of issues.  The trial court heard oral argument on the parties’ respective motions in limine on September 26, 2023.  1T.  Plaintiff’s counsel filed a motion in limine seeking a ruling that Plaintiff was permitted to play the audio portion of a police dashcam video depicting the scene of the accident immediately after the police arrived.  The trial court granted Plaintiff’s motion by Order dated September 26, 2023.  Da41.  [...] filed a motion in limine seeking a ruling that barred from evidence at trial any information concerning Mr. [...]’s prior criminal convictions.  The trial court granted [...]’s motion by Order dated September 26, 2023.  Da42.  Several other motions that are not germane to this appeal were filed and ruled on by the trial court on September 26, 2023.  Da43, Da44, and Da46.  [...] filed a motion for reconsideration of the trial court’s Order granting [...]’s motion to bar evidence of his criminal convictions.  The trial court heard argument on [...]’s motion for reconsideration on October 3, 2023, and denied the motion by Order dated October 3, 2023.  Da45.  The matter proceeded to trial on October 3, 2023.  2T.  The case was tried before a jury on October 3, 2023, October 4, 2023, and October 5, 2023. \(^2\)  During their deliberations, the jury asked the following questions:  “[C]an you provide guidance on money award? Is there a range or cap? Was there an amount requested?”  5T:110-9 to 11.  The trial court responded to each of the questions separately.  The trial court responded to the first question by re-reading the full jury charge on damages.  5T:115-25 to 119-6.  The trial court simply responded to the second question by stating “no. ”  5T:119-7.  In response to the third question, the trial court stated, “In New Jersey attorneys and the parties are not allowed to request a certain amount. ”  5T:119-9 to 10.  The jury returned a verdict concluding that both [...] and [...] were negligent and that their respective negligence was a proximate cause \(^2\)The trial transcripts have been designated with the following abbreviations: October 3, 2023 (2T); October 4, 2023 (3T, Vol. I); October 4, 2023 (4T, Vol. II), and October 5, 2023 (5T). of the accident.  5T:120-25 to 122-15; Da272.  The jury apportioned liability between [...] and [...] by assigning 60% of the fault to [...] and 40% to [...].  5T:122-19 to 123-2; Da273.  The jury then awarded Plaintiff $3,500,000 in damages.  5T:123-6 to 14; Da273.  [...] and [...] each filed motions for a new trial, remittitur, and for judgment notwithstanding the verdict following the trial.  The trial court heard oral argument on the [...]’s motion on November 16, 2023.  6T.  The trial court denied [...]’s motion by Order dated November 17, 2023.  Da225.  The parties agreed to a stay of the judgment upon the posting of a Supersedeas Bond by [...].  Da210.  This office entered an appearance as co-counsel for [...] on December 4, 2023.  Da212.  [...] filed a Notice of Appeal from the jury’s verdict and the trial court’s Order denying [...]’s motion for a new trial, remittitur, and judgment notwithstanding the verdict.  Da213.  [...] also filed an appeal from the jury’s verdict.  Da265.  [...]’s appeal was dismissed following a settlement with Plaintiff.  Da270.  --- 3  The trial court conducted a separate hearing on [...]’s motion for a new trial and denied that motion by Order dated November 3, 2023.  [...] has withdrawn his appeal, and therefore, we have not included [...]’s motion for a new trial in this appeal.  STATEMENT OF FACTS