Motion in limine to exclude prior-accident evidence — filed with EDLA.

Drafted deposition outline v2 for defendant's safety director — 18 topics, 42 exhibits linked.

Meet-and-confer w/ opposing on ESI scope — Zoom · 45 min.

Client update sent: trial prep status, upcoming depositions, expert reports.

Retained biomechanical expert Dr. Patel — engagement letter countersigned.