Defendant Motion in Limine

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Plaintiff’s witnesses should be ordered to refrain from offering any evidence as to Defendants’ state of mind, and witness and counsel should be ordered not to introduce any evidence and argument that Defendants acted willfully, wantonly, purposefully, heedlessly, recklessly, consciously, callously, without regard to the consequences, or the like.

Spyglass

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Plaintiff’s witnesses should be ordered to refrain from offering any evidence as to Defendants’ state of mind, and witness and counsel should be ordered not to introduce any evidence and argument that Defendants acted willfully, wantonly, purposefully, heedlessly, recklessly, consciously, callously, without regard to the consequences, or the like.

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