Greetings,
This thread is not about the "NO-DRIVER LICENSE" issue. It is about a car that is registered to the state of Washingtn and the yearly registration tab had expired several days .

This is about the state statute saying the Tow company is not allowed to go on police policy but, must obey the law. They did not and as a result must be held accountable. The Tow company brought in the NO DRIVERS LICENSE which is outside the 4 corners of the original Complaint and should be removed with a Motion In Limine.

Don't you agree? Can you comment on the content of the suit?

The attorney for the defendants just mailed a letter with an attached Motion, not yet filed, threatening to put it into play if we do not dismiss the complaint. It is pursuant to sec. 57.105(1) and 57.105(40) GIVING US 21 DAYS to dismiss!!!!! OR ELSE.

Here is our Motion in Limine:
MOTION IN LIMINE TO EXCLUDE DEFENDANT’S EXHIBIT 1 AND ANY FUTURE AND PAST HISTORICAL TESTIMONY THERETO
COMES NOW the Plaintiff, xxxxxxxxxxxx Ministries, by and through the undersigned Karl xxxxxxxx hereby moves for an order for Motion in Limine to Exclude Defendant’s Exhibit 1, xxxxxxxxx Police Department Offense/Incident Report and any witness or testimony thereto and as ground states:
FACTS 1. The Defendant’s Exhibit 1 testifies to happenings outside the four corners of this suit. No one is denying that the testimony is there. We are denying that it has anything to do with this suit therefore has no standing in court as a valid fact for or against this case. It is inadmissible evidence to this case.
2. Testimony of Exhibit 1 could put an unnecessary, unfavorable and derogatory light on the Plaintiff for no good cause. We are concerned with the xxxxxxxxxx Towing’s actions after the Exhibit 1 immaterial fact as to xxxxxxxxxx Towing’s lawful material duties.
3. Any testimony of an expert witness of the Exhibit 1 should not be allowed when it serves to place inadmissible evidence before a jury. Linn v. Fossum, 946 So. 2d 1032,1038 (Fla.2006); also see Erwin v. Todd, 699 So. 2d 275, 277 (Fla. 5th DCA 1997); Riggins v. Mariner Boat Works, Inc., 545 So. 2d 430, 432 (Fla. 2nd DCA 1989) are a line of cases that “prohibits the use of expert testimony merely to serve as a conduit to place otherwise inadmissible evidence before a jury.”
4. Any Defendants’ experts or witnesses who would attempt to discredit the Plaintiff, placing otherwise inadmissible evidence before a jury and attacking their credibility and character through speculative testimony. The crux of these possible experts or witnesses’ testimony is that Plaintiff, in regards to any non-material historical facts, could be used as inconsistent, not credible, and, exaggerating, so that Plaintiff would not be believed.
5. Such testimony would be wholly improper and would be inadmissible for five (5) reasons:

(1) It would consist entirely of guesses, conjecture and speculation (i.e., mere suspicions without premise of fact);(2) The nature of this testimony does not require any special knowledge or experience in order for the jury to form it’s conclusions;(3) Such testimony would be an attack on the Plaintiff’s credibility and character by innuendo and suspicion;(4) The expert cannot serve as a conduit to place otherwise inadmissible evidence before a
jury; and (5) The highly prejudicial impact of such testimony substantially outweighs any probative value.
CONCLUSION
In the current political climate, there is no doubt that plaintiffs may be perceived as “Constitutional patriots” before they ever walk into a courtroom. This is a difficult enough burden to overcome without the additional highly prejudicial burden of “secondary gain” testimony at trial. “Secondary Gain” testimony seeks to imply, without any factual basis whatsoever, that the particular Plaintiff in this particular case is suing for financial gain. There is absolutely no evidence or empirical data to substantiate this. This type of non-evidentiary insinuations changes the jury trial from a search for the truth to a political “negative ad campaign” against the plaintiff. It diverts the jury’s attention from the evidence presented by both sides to “charged words” and innuendos being thrown at them by the defense.
Accordingly, by its very nature this type of testimony should be and by law is not admissible in a fair trial.
WHEREFORE, Plaintiff, xxxxxxxxxxxxx Ministries by and through Karlxxxxxxxxxxx move this Honorable Court for an Order striking Exhibit 1 and any future Defendant’s evidence, exhibits, witnesses or expert witnesses they may call for testimony outside the four corners of the Complaint, and for such further relief as this Honorable Court deems just and proper.

Again, I must reiterate, the DEFENDANTS ATTORNEY placed the poison on the record about the RIGHT TO TRAVEL, and CONSTITUTIONAL PATRIOTS STUFF not me. We are doing our best to approach this in PROPER COURT ETIQUETTE and PROCEDURES and WRITINGS FROM YOUR CLASSES.
Karl

Then, Ponderosa1, you know how to argue against the defendant's attorney who is apparently an ignorant person.