DEFENDANT COLONIAL SAVINGS, F.A.’S MOTION IN LIMINE PAGE 1 

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DEFENDANT COLONIAL SAVINGS, F.A.’S MOTION IN LIMINE

 COMES NOW Defendant Colonial Savings, F.A. (“Colonial” or “Defendant”) files this, 

their Motion in Limine, and would thereby respectfully show unto the Court the following: 

I. 

Defendant moves the Court for an Order, prior to the voir dire examination of the jury 

panel in this cause, that Plaintiff and Plaintiff’s attorneys and representatives and any and all 

witnesses called on behalf of Plaintiff be instructed to refrain from any mention or interrogation, 

directly or indirectly, in any manner whatsoever, including the offering of documentary 

evidence, concerning the matters set forth in Exhibit A. If any attorneys wish to propose a theory 

of admissibility concerning these matters, Defendant requests the Court to order that counsel first 

must request a ruling from the Court outside the presence and hearing of all prospective jurors 

and jurors ultimately selected in this cause. 

II. 

The matters set forth in Exhibit A attached hereto and incorporated herein by reference 

would not be admissible evidence for any purpose on proper and timely objection because they 

have no rational relationship to any probable or controlling fact issue in dispute, nor do they have 

IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

SAN ANTONIO DIVISION 

 

ANN MARIE ATTRIDGE, § 

§ 

§ 

 Plaintiffs, § 

§ 

v. § Civil Action No. 5:20-cv-00205-OLG 

§ 

COLONIAL SAVINGS, F.A. and 

TRANSUNION, LLC, 

§

§ 

§ 

 Defendant. § 

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a tendency to make the existence of any fact that is of consequence to the determination of the 

action more probable or less probable than it would be without the evidence. 

III. 

Permitting interrogation of witnesses, comments to jurors, or prospective jurors, or offers 

of evidence concerning any of the matters set forth in Exhibit A would prejudice the jury and 

sustaining objections to such questions, statements or evidence introduced by counsel or 

witnesses will not prevent prejudice but will reinforce the development of questionable evidence. 

IV. 

Further, the probative value of the matters set forth in the Exhibit A is substantially 

outweighed by the danger of unfair prejudice, confusion of the issues or misleading the jury and 

as such should not be admissible for any purpose in the cause and to permit the mentioning of 

such matters would prejudice the jury even with sustaining of any objection to such matters. 

WHEREFORE, PREMISES CONSIDERED, Defendant requests that this Motion in 

Limine be granted and an appropriate Order signed and entered by the Court consistent with this 

Motion. 

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DEFENDANT COLONIAL SAVINGS, F.A.’S MOTION IN LIMINE PAGE 3 

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Respectfully submitted, 

By: /s/ Mark D. Cronenwett 

 MARK D. CRONENWETT

 Attorney in Charge 

 Texas Bar No. 00787303 

mcronenwett@mwzmlaw.com 

MACKIE WOLF ZIENTZ & MANN, PC 

14160 N. Dallas Parkway, Suite 900 

Dallas, Texas 75254 

(214) 635-2650 

(214) 635-2686 (Fax) 

ATTORNEYS FOR DEFENDANT 

COLONIAL SAVINGS, FA 

CERTIFICATE OF SERVICE 

I hereby certify that on July 13, 2022 a true and correct copy of the foregoing was served 

via ECF notification on the following counsel of record: 

William M. Clanton 

Law Office of Bill Clanton, PC 

926 Chulie Drive 

San Antonio, TX 78216 

210-226-0800 

210-338-8660 FAX 

bill@clantonlawoffice.com

 /s/ Mark D. Cronenwett 

MARK D. CRONENWETT 

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