UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

CARRIE ANN SEDOR,

Plaintiff,

Case No. 2:24-cv-3714 v. Judge Edmund A. Sargus, Jr.

Magistrate Judge Elizabeth P. Deavers STATE FARM FIRE AND CASUALTY

COMPANY,

Defendant.

ORDER This matter is before the Court on Defendant State Farm Fire and Casualty Company’s Motion in Limine to Strike Plaintiff’s Lost Business Income Claim. (ECF No. 41.) Plaintiff Carrie Ann Sedor responded (ECF No. 46) and Defendant replied (ECF No. 49). For the reasons below, the Court GRANTS Defendant’s Motion in Limine to Strike Plaintiff’s Lost Business Income Claim. (ECF No. 41.) ANALYSIS Motions in limine allow the Court to rule on the admissibility of evidence before trial to expedite proceedings and provide the parties with notice of the evidence on which they may not rely to prove their case. Bennett v. Bd. of Educ. of Washington Cnty. Joint Vocational Sch. Dist., C2-08-CV-0663,

, at *1 (S.D. Ohio Oct. 7, 2011) (Marbley, J.). Neither the Federal Rules of Evidence nor the Federal Rules of Civil Procedure explicitly authorize a court to rule on an evidentiary motion in limine, but the United States Supreme Court explained that the practice of ruling on such motions “has developed pursuant to the district court’s inherent authority to manage the course of trials.” Luce v. United States,

, 41 n. 4 (1984). Evidentiary rulings are made subject to the district court’s sound discretion. Frye v. CSX Transp., Inc.,

(6th Cir. 2019). Defendant moved this Court for an Order in limine “striking any and all claims Plaintiff Carrie Ann Sedor may have for lost business income, along with excluding all evidence, trial

testimony or reference to Plaintiff’s lost business income claim.” (ECF No. 41, PageID 1273.) Defendant argues that Plaintiff “failed to itemize, specify, quantify or provide any information about her claimed lost business income damages” and, since discovery has closed, she “should be barred from recovering any claimed lost business income damages and any proof of such damages should be excluded at trial.” (Id.) In response, Plaintiff states that she “does not intend to pursue lost business income as an item of damages at the trial of this matter.” (ECF No. 46, PageID 1318.) Plaintiff did not otherwise oppose Defendant’s motion in limine. Therefore, Defendant’s uncontested motion in limine is GRANTED. Plaintiff is precluded from presenting any claim for lost business income at the trial of this matter, as well as any evidence about or reference to a lost business income claim.

CONCLUSION

For the reasons stated herein, the Court GRANTS Defendant State Farm Fire and Casualty Company’s Motion in Limine to Strike Plaintiff’s Lost Business Income Claim. (ECF No. 41.) This case remains open. IT IS SO ORDERED. 10/22/2025 s/Edmund A. Sargus, Jr. DATE EDMUND A. SARGUS, JR. UNITED STATES DISTRICT JUDGE