IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISON

FASCIA EDWARDS, )

)

Plaintiff, )

) No. 12 C 371

v. ) Hon. Marvin Aspen

)

ILLINOIS DEPARTMENT OF FINANCE )

PROFESSIONAL REGULATIONS, et al. )

)

Defendants. )

DEFENDANT’S UNOPPOSED GENERAL MOTIONS IN LIMINE NOS. 1-4 

Defendant, by and through its attorney, Lisa Madigan, Attorney General for Illinois,

hereby moves this Honorable Court to enter the following orders in limine which are unopposed 

by Plaintiff:

Motion in limine No. 1: Bar Witnesses from the Courtroom.

1. Defendant hereby requests that the Court enter an order barring any witnesses 

who may or will testify in this matter, other than parties to this action, from being present in the 

courtroom until after their full testimony is presented.

Motion in limine No. 2: Admit Joint Exhibits.

2. Defendant hereby requests that the Court enter an order admitting all joint 

exhibits at the outset of the trial.

Motion in limine No. 3: Bar Any Mention of Settlement Discussion or Negotiation.

3. Evidence of (1) furnishing or offering or promising to furnish, or (2) accepting or 

offering or promising to accept, a valuable consideration in compromising or attempting to 

compromise a claim which was disputed as to either validity or amount, is not admissible to 

prove liability for or invalidity of the claim or its amount. Evidence of conduct or statements 

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made in compromise negotiations is likewise not admissible. Fed. R. Evid. 408. 

Any comment or reference to any settlement negotiations including any offers of 

settlement, settlement demands, offers or compromise, the amounts of such offers or demands 

and any rejection of such offers or to prove or disprove the validity of the amount of a disputed 

claim or to impeach by a prior inconsistent statement or contradiction should be barred and no 

evidence or argument should be presented during the trial of this matter of any settlement 

negotiations and comments or statements made during the course of this litigation. 

Motion in limine No. 4: Allow Counsel to Communicate With the Jury After Verdict.

4. Defendants move the Honorable Court to allow counsel for the parties to 

communicate with the jury after a verdict is entered in this matter.

WHEREFORE, based on the foregoing, the Defendants move this Honorable Court to 

enter the orders in limine as set forth above and for such further relief that the Court finds 

reasonable and just.

Respectfully Submitted,

LISA MADIGAN s/ Kevin Lovellette

Illinois Attorney General Kevin Lovellette

Assistant Attorney General

General Law Bureau

100 W. Randolph Street, 13th Floor

Chicago, Illinois 60601

(312) 814-3720

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CERTIFICATE OF SERVICE

The undersigned certifies that on March 16, 2017, he electronically filed the foregoing 

document with the Clerk of the Court for the United States District Court for the Northern 

District of Illinois using the CM/ECF system. All participants in the case are registered CM/ECF 

users who will be served by the CM/ECF system.

s/ Kevin Lovellette

Case: 1:12-cv-00371 Document #: 209 Filed: 03/16/17 Page 3 of 3 PageID #:2805