GOSSETT v. JIUDICY INC

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IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF GEORGIA
VALDOSTA DIVISION
SUSAN GOSSETT, 	:
:
Plaintiff, 	:
:
v. 	: 	CASE NO.: 7:24-CV-00067 (WLS)
:
JIUDICY INC d/b/a 	:
LABOR FINDERS, 	:
:
Defendant. 	:
:
:
ORDER
Before the Court is Plaintiff’s Motion in Limine (Doc. 41) (“the Motion”). The Court
held a pretrial conference in this case on July 15, 2026. (Doc. 43). At the conference, Plaintiff
and Defendant indicated a desire for a speedy resolution of any motions in limine. Defendant
responded to the Motion on July 20, 2026. (Doc. 44).
The true purpose of a motion in limine is to avoid the introduction of evidence at trial
that is “clearly inadmissible on all potential grounds” and could irretrievably impact the
fairness of trial. Royal Marco Point 1 Condo. Ass’n v. QBE Ins., No. 2:07-cv-16, 2011 WL 470651,
at *2 (M.D. Fla. Feb. 2, 2011) (citing Luce v. United States, 469 U.S. 38, 41 (1984)). But the
context at trial often determines the admissibility of evidence and, for this reason, “i[n] limine
rulings to admit or exclude evidence are always preliminary and conditioned on what the
evidence shows at trial.” Ohler v. United States, 529 U.S. 753, 757 n.3 (2000). Furthermore, a
trial court can promptly instruct a jury to disregard improper testimony or inadmissible
evidence, and “[i]n many such cases the jury can and will follow the trial judge’s instructions
to disregard such information.” United States v. Astling, 733 F.2d 1446, 1455 (11th Cir. 1984);
United States v. Fuentes, 521 F. App’x 911, 911 (11th Cir. 2013). A motion in limine ruling has
no impact on counsel’s duty to make proper and contemporaneous objections at trial as to
any evidence or argument they consider inadmissible or improper. See Cephus v. CSX Transp.,
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Inc., 771 F. App’x 883, 894–95 (11th Cir. 2019). As such, the Court disfavors motions in limine
made for other purposes.
Plaintiff seeks a ruling on four exhibits, citing Federal Rules of Evidence 401, 402, 403,
801, and 802. Plaintiff first argues that the EEOC Dismissal and Notice of Right to Sue Letter
is unduly prejudicial and likely to mislead the jury. (Doc. 41 at 2). Defendant argues that
Plaintiff has not made any specific reference to how this piece of evidence unfairly prejudices
her. (Doc. 44 at 4). Trial is the appropriate context for the Court to determine prejudice, and
Plaintiff has not demonstrated prejudice so severe that it could not be cured with instructions
to the jury. Accordingly, Plaintiff’s objections to this piece of evidence are premature.
Plaintiff’s motion as to the EEOC Dismissal and Notice of Right to Sue Letter is DENIED,
without prejudice.
Plaintiff argues that Defendant’s EEOC Position Statement should be excluded as self-
serving hearsay. (Doc. 41 at 3). Defendant responded, arguing that Plaintiff’s EEOC Charge
of Discrimination, which both Parties have proposed as an exhibit for trial, contains self-
serving hearsay from Plaintiff. (Doc. 44 at 3). Defendant goes on to propose that both position
statements, each constituting self-serving hearsay, be introduced at trial on equitable grounds.
(Id.) So the Parties and the Court may consider this proposal, Plaintiff’s motion as to
Defendant’s EEOC Position Statement is DENIED, without prejudice.
Plaintiff argues that the OSHA documents are collateral and likely to confuse the jury
about the issues in this case. (Doc. 41 at 3). Defendant responded, arguing that Plaintiff is the
one who made an issue out of the OSHA Complaint throughout this case and that she has
not agreed to remove any reference to the OSHA Complaint from any arguments she may
make at trial. (Doc. 44 at 1–2). The OSHA documents appear unrelated to the claims
remaining for trial and highly likely to confuse the jury. However, if Plaintiff indeed makes an
issue of the OSHA Complaint at trial, it might be improper for the Court to exclude the related
documents. Accordingly, Plaintiff’s motion as to the OSHA documents is DENIED, without
prejudice.
Upon review, the Court has not identified any evidence specifically referenced which
cannot be addressed effectively by contemporaneous objection, motion to exclude, or by
appropriate curative or limiting instructions to the jury by the Court. Accordingly, Plaintiff’s
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Motion in Limine (Doc. 41) is DENIED, without prejudice. Nothing in this Order, however,
should be construed as limiting the Parties from raising these objections to evidence at trial, if
justified. The Court further notes that agency actions might be admissible for certain limited
purposes, notwithstanding that the jury will not consider the same for determining whether
the actions or decisions of the agency were correct. In that circumstance, if otherwise
permissible, the Court would give the jury an appropriate limiting instruction.
SO ORDERED, this 22nd day of July 2026.
/s/ W. Louis Sands
W. LOUIS SANDS, SR. JUDGE
UNITED STATES DISTRICT COURT
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