Motion in Limine 001-negligent hiring-joint and several liability-state court

Motion in Limine 001: negligent hiring and joint and several liability in state court:

Is evidence defendant trucking company failed to train driver admissible?

Jordan v. Cates discussion.

Under Oklahoma law, plaintiff entitled to pursue multiple, alternative theories of recovery.

Proper notice of claim.

Insurance coverage of punitive damages for employer’s conduct which played a role in the harm proper under public policy.

Comparative negligence requires allocation of fault that cannot be done in absence of evidence.