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 Defendant Jiudicy, Inc.’s Motions in Limine (“Motion”) and
Objection to Plaintiff’s Witnesses and Exhibits (“Objection”). (Doc. 40). 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. Plaintiff
responded to the Motion on July 20, 2026. (Doc. 45).
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
for other purposes.
Defendant seeks a ruling on six evidentiary motions, the last of which incorporates
Defendant’s evidentiary objections. The Court will first address the broad category the first
five motions fall into and then the objections. First, Defendant requests an impartial jury and
asks the Court to exclude any reference to a failure to call an equally available witness,
argument for jury nullification, character evidence about the Plaintiff, and hearsay. Essentially,
these are all “follow-the-law” objections requiring the Court to admit only admissible evidence
relevant to the claims in the current case or asking the Court to recognize established rules of
evidence. Such objections are improper. See e.g., Huddleston v. United States, No. 2:19-CV-14048,
2019 WL 6828148, at *2 (S.D. Fla. Dec. 13, 2019). To the extent it needs to be said, the Court
will conduct its voir dire to ensure an impartial jury, Parties must follow the law, and the Court
will faithfully apply the applicable rules of evidence at trial. Accordingly, Defendant’s motions
One, Two, Three, Four, and Five are all DENIED, without prejudice. Defendant may raise
such 	objections, 	to 	the 	extent 	justified, 	as 	it 	relates 	to 	specific 	testimony 	if
offered by Plaintiff at trial.
Defendant objects to, and seeks to exclude, Plaintiff calling her treating physicians as
witnesses and the admission of doctors’ notes and wage documents. Defendant argues the
physicians’ testimony should be excluded because they were not previously disclosed as
witnesses or expert witnesses. (Doc. 40-1 at 1–2). However, Plaintiff has agreed to remove the
physicians from the pretrial order and not call them at trial. (Doc. 45 at 6). Accordingly,
Defendant’s objection to Plaintiff calling her physicians as witnesses, as incorporated in their
motion in limine, is DENIED, as moot.
Defendant objects to the admission of doctors’ notes as inadmissible hearsay and an
impermissible use of lay testimony to introduce the testimony of undisclosed expert witnesses.
(Doc. 40-1 at 2). The hearsay objection is another improper “follow the law” objection, which
is due to be denied for the reasons discussed above. Even so, Plaintiff responded to the expert
witness objection, stating she does not intend to use any lay witness as an expert witness or
offer undisclosed expert opinions through lay testimony. (Doc. 45 at 4). Indeed, “[a] treating
physician is not considered an expert witness if he or she testifies about observations based
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on personal knowledge, including the treatment of the party.” Williams v. Mast Biosurgery USA,
Inc., 644 F.3d 1312, 1317 (11th Cir. 2011). Accordingly, the expert witness objection is
DENIED, without prejudice.
Finally, Defendant objects to the admission of Plaintiff’s wage records because they
were not disclosed during discovery and constitute hearsay. The hearsay objection is another
improper “follow the law” objection, which is again due to be denied for the reasons discussed
above. Even so, Plaintiff responded to the disclosure argument, saying the wage records all
concern the disputed issues of damages and mitigation. (Doc. 45 at 5–6). The Court will assess
whether the prejudice of late disclosure is significant enough to outweigh the probative value
of these records when it has the necessary context at trial. Accordingly, the disclosure
objection to the wage records 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, Defendant’s
Motion in Limine (Doc. 40) 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
appropriate.
The Court notes that evidence produced during discovery in response to a discovery
request is considered authenticated for trial purposes as set forth in the Discovery Order
(Doc. 7), unless otherwise noted upon production. The presumption of authentication does
not apply to evidence not produced during discovery. The Parties are so noticed.
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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