Practice Tip: Keep a List of Motions in Limine
Evan Shaeffer passes along a tip for litigators: start a memo early in a lawsuit and keep track of evidentiary issues as they arise. Although you will still end up poring over the entire file during final trial preparation, at least you can focus on presenting evidence. Evan specifically mentions a list of motions in limine to exclude evidence, but I'd take it a step further and keep a running tally of briefs you will need to draft in favor of evidence as well. If you've got evidence of post-incident changes, for example, you might as well plan on a bench brief to explain why it is not a subsequent remedial measure or why it is admissible notwithstanding Rule 407.