Your supervising attorney is preparing for a trial. The Plaintiff inthis case, Billy Bob, began his employment with Widget World Co., theDefendant, on January 2, 1990. Mr. Bob worked as a truck driver forWidget World, initially in its Blackacre terminal, and then in itsWhiteacre terminal. Widget World is a widget company that utilizeshazardous materials on a daily basis. On November 11, 20015, Mr. Bob wasterminated.

In September of 2015, Mr. Bob and several other Widget Worldemployees were sent to Whiteacre to refurbish a floor in the plant withepoxy product. There is a question as to whether Mr. Bob followedinstructions in refurbishing the floor in the plant.

Thereafter, on November 9, 2015, Mr. Bob suffered from a workplaceinjury, and reported it to the company. Mr. Bob has had on-goingrheumatoid arthritis, and in October of 2015, he stepped off the backend of a trailer and jarred himself when he hit the ground. A few weekslater he felt such a sharp pain from his injury that he could hardlywalk. His pain was so intense that he was taken to the local emergency room and received several painkiller injections. Heinformed the company that he was going to file a worker's compensationclaim pertaining to that injury. When Mr. Bob informed Mr. Widgetall,Widget World's Safety Director, about his intention, the conversationbetween the two became heated.

At a meeting on November 11, 2015, Mr. Bob reiterated his intentionto file a worker's compensation claim for his injury. Mr. Mitchell, thesafety director for Roeder, then produced a termination letter to Mr.Bob, alleging insubordination and terminated Bob's employment. The nextday, Mr. Bob filed a workers' compensation claim.

Mr. Bob initiated this case, alleging that he was terminated inrelation for his intent to file a workers' compensation claim, inviolation of Whiteacre law. Widget World has filed a counterclaimagainst Mr. Bob, alleging defamation. The trial is set to commence intwo weeks, and motions in limine are required to be filed this week.Suzy Cue is your supervising attorney at Alpha & Beta LLC, 432 BrownCt, Whiteacre. She would like you to prepare a motion in limine to keepany mention of the following evidence out of court:

• Any mention of Billy's psychological counseling, which he has been receiving for the last 5 years
• Any mention of Billy's previous conviction for possession of marijuana
• Billy's request for $50,000 in exchange for his dismissal of the case

Using this sample provided by Suzy, as well as your own research, draft a motion
in limine using the laws of your state.