You represent the DEFENDANT in an auto accident. During deposition your client disclosed the following facts:

1. Your client had personal problems on the day of the incident which may have contributed to his alleged inattention.

2. Your client has three moving violation tickets one of which is exactly what is alleged against him in this lawsuit.

3. Your client had one beer with friends after work, with dinner, and just prior to the incident. No police were ever called.

4. Your client was wearing his prescription sunglasses at the time of the incident (after dark) because his regular glasses were left at home that day.

5. Your client was convicted of a felony 8 years ago for automobile theft.

Pick the facts that you believe could be excluded from being heard by a jury.

Draft a Motion in Limine pursuant to Evidence Code 352 and argue for exclusion of your selected evidence. Beware that not all factsgiven should be the subject of your motion.

After writing the motion tell me why you did not include the evidence you left out of the motion.