Christine Connors has sued Capital Group, Inc. ("CGI") for wrongful termination,sexual harassment, and retaliation. Christine worked for CGI in its marketing departmentfrom 2005 - November 1, 2014 when she was terminated, ostensibly due to poor performance. Ms. Connors alleges that the real reason for the termination was her refusalto succumb to William Capital's, President of CGI, romantic advances. She alleges thaton October 15, 2014, she complained to her boss, Jon Bosman that Mr. Capital hadinvited her to a "business dinner" but upon arrival at the restaurant, Ms. Connors realized there were no clients present and that Mr. Capital intended for the evening to be a romantic encounter. Ms. Connors alleges her termination was in retaliation for her rejection of Mr. Capital's romantic advances and her complaining of them to Mr. Bosman. Discovery has revealed that ten years prior to Ms. Connor's employment with CGI, she worked as a dancer in a Strip Club in Hollywood. Ms. Connors is concerned that if the jury learns of her prior occupation, they will be prejudiced against her and notkeep an open mind as to her claims.

Trial is set for January 15, 2016 with the FSC on January 6, 2016.

Your firm represents Ms. Connors. The partner on the case asked you to prepare the following: (1) Draft a Motion in Limine (no more than 3 pages) set for hearing at theFSC on behalf of plaintiff seeking to exclude her employment as an adult entertainmentdancer (2) a Witness List, (3) Exhibit List and (4) Joint Short Statement of the Case and (5) Determine when these documents must be filed. For the witness list, add the namesand titles of two additional witnesses who should testify at trial (make them up,demonstrating creativity and understanding of the assignment). Similarly, for the exhibitlist, add one additional exhibit (something made up) that should be presented at trial.

The witnesses identified by plaintiff are: (1) Christine Connors, (2) Jon Bosman, (3) William Capital, (4) Dr. John Expert, CPA, (5) Mellie Resource, Director of HumanResources for Capital Group Inc., and (6) Dan Remedy, M.D. - Plaintiff's Psychiatrist. The exhibits are: (1) Plaintiff's Personnel File from Capital Group Inc., (2) Plaintiff's W-2 Forms from 2005-2014, (3) Plaintiff's Resume, (4) List of all Employerswhere Plaintiff has applied for employment post termination, (5) Dr. Expert's Calculationof Plaintiff's Damages, and (6) Plaintiff's medical records from Dr. Remedy