You are Defendant's lawyer in a murder trial, State v. Paulson. You need to draft a motion in limine regarding evidence against defendant. The evidence at issue regards a prior death, some [-15] years ago. You must write the best argument that the evidence at issue (described on the next page) should be inadmissible, while recognizing the limitations of your argument. Underlying Facts of this case Defendant is accused of killing his wife, Katherine Paulson. Defendant claims that his wife fell down a long set of stairs to her death; the Prosecution argues that his wife was killed by blunt force trauma, and then pushed down the stairs. Katherine Paulson had been an executive at a local company. On Saturday, April 3, [-6] defendant placed a 911 call at 2:45a.m.. The defendant said, "My wife's had an accident, she's still breathing." He then told the operator that "[s]he fell down the stairs," and he repeated that "[s]he's still breathing." The defendant said that Kathleen was not conscious. When asked how many steps she had fallen down, the defendant, after a pause, said, "15, 20, I don't know." The operator told the defendant that "somebody's dispatching the ambulance while I ask you questions." Mary Allen, the 911 operator, asked two more questions, and the caller "disconnected." The paramedics arrived. One paramedic will testify based on his deposition as follows: I, Paramedic Jim Thym, am a fifteen-year-veteran of emergency medical service. I arrived at the scene less than 10 minutes after the 911 call was made. ... An enormous amount of blood [was] involved. A lot of the blood that [was] on the walls [was] dry. The blood under her head was ... coagulated. it had already clotted and started to harden. We could see ... dried blood on the steps, and also on the wall. And it also looked like it had been wiped away or wiped on. It had been smeared, instead of just blood droplets soaking down the wall. His required "trip ticket" report noted: "Upon arrival [I] found [a] 47-year-old female at the bottom of the steps with blood in large volume over walls and floor." The paramedics asked the defendant what had happened. He "told ... [them] that he had just went [sic] outside to turn off the lights, and came back in and found her at the bottom of the steps." Additional Facts according to the Defendant Defendant and Katherine met in [-25], when they began to fall in love. Katherine was a recently separated single mom raising a young daughter by herself, because her husband, Frank Daulphin, had had numerous affairs and she had left him. The new couple connected in a way that few people who are really, really lucky in life have a chance to connect. Defendant describes Katherine as his soulmate. They began to live together in [-23], when Defendant purchased a house, where the blended family lived. (Defendant's two sons, Katherine's daughter, and the two daughters of Eleanor - see below). In [-19] the defendant and Katherine married (after his divorce from his first wife became final). According to friends and family, what kept them together, had nothing to do with anything tangible ... it was a love that absolutely everyone who saw them or knew them understood and recognized, and envied, truth be told. Defendant's step-daughter (Katherine's daughter) will provide testimony that defendant had restored Katherine's "dignity and pride," which had been crushed by the collapse of her first marriage, and that the defendant "was able to restore her strength and confidence, and to show her that she could find true love. There is no evidence that Katherine discovered anything new about Defendant's activities before her death such that Defendant would have any motive to kill his wife, or that Defendant was actively involved in any relationship outside of his marriage.Evidence at issue Eleanor Reynolds worked as a teacher and her husband Grant was an officer in US Army. In [-34] to [-31] the couple lived in Southern California, just outside of San Diego. Both were good friends with defendant and his first wife, Penelope. After Grant's death in [-31], defendant began to help Eleanor with funeral arrangements, financial matters, and general support. About a year after her husband's death, Eleanor and her two daughters moved to a house down the street from the Paulsons in San Diego. Defendant continued to help care for the Reynolds family during the next year. One morning, at 7:15am on September 28, [-28], Alicia, the au pair to the Reynolds children, found Eleanor dead at the bottom of the main staircase in her home. A friend and co-worker of Eleanor's, Carrie, will testify that she arrived at the house around 9am. Based on her deposition, she will describe the scene as this: Defendant was there, talking mainly with the police and other official personnel at the house. Along with the defendant and those officials, several other people were in the small foyer area; two neighbors of the Reynolds family, Penelope Paulson (defendant's first wife), and a taxicab driver. Eleanor's body was at the bottom of the stairs. She was wearing a pair of yellow boots and was partially covered by a coat. There was blood sprayed down the wall of the open staircase, blood on the all opposite the foyer area, blood on a chest and footlocker, and a pool of blood underneath Eleanor's body. Me, her husband, and someone else, probably defendant, helped clean up the blood after Eleanor's body was taken away. Also, on the Thursday before Eleanor died, Eleanor complained about headaches and scheduled a doctor's appointment for the following week. Eleanor's sister, Mary, will testify that defendant called her later in the day on September 28, [-28] and informed her of Eleanor's death. He said she accidentally fell down the stairs and died. Sometime near the funeral, Mary spoke with Defendant regarding the events surrounding her sister's death. Defendant told her that he and his wife had the Reynolds family over for dinner and he returned with them to help get the girls to bed and take out the trash. Pursuant to Eleanor's will, defendant and his first wife became guardians of the two daughters, Michelle and Mandy, and they received various household goods and benefits associated with the children. Two days after her death, Eleanor's autopsy was performed. The autopsy listed the cause of death as "intracranial hemorrhage, cerebellar-brain stem secondary to Von Willebrand coagulation abnormality...scalp lacerations secondary to terminal fall." This investigation concluded that there were "no indications of foul play." 22 years later, in June [-6], Eleanor's body was exhumed and an autopsy performed again. This autopsy revealed contradictory findings, determining that the cause of death was blunt force trauma to the head. The doctor performing the autopsy noted multiple injuries, including marks on the head, seven distinct lacerations, and injuries to the left hand, forearm, and back. The doctor opined that the "intracranial hemorrhages noted at the firs autopsy were primarily the result of blunt trauma rather than any underlying natural disease process. [Note: the date format of [-X] means X years ago, so [-6] is 6 years ago, and [-22] is 22 years ago, etc.]