WILLIAM JEFFREY BURNETT V. CONSECO LIFE INSURANCE COMPANY

District Court, S.D. Indiana·Decided June 4, 2025·No. 1:18-cv-00200·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

WILLIAM JEFFREY BURNETT, ) JOE H CAMP, ) ) Plaintiffs, ) ) v. ) No. 1:18-cv-00200-JPH-KMB ) CNO FINANCIAL GROUP, INC., ) CNO SERVICES LLC, ) ) Defendants. )

ORDER ON MOTIONS IN LIMINE The parties have filed a combined 33 motions in limine. Dkt. 565; dkt. 572. For the reasons below, those motions are GRANTED in part and DENIED in part. A table summarizing the motions and rulings is attached as Appendix A. Consistent with the Court's instructions at the final pretrial conference, and to avoid wasting the jury's time, counsel must raise reasonably foreseeable evidentiary issues in advance outside the presence of the jury— generally before or after the trial day, over lunch, or at a break. I. Applicable Law "Motions in limine are well-established devices that streamline trials and settle evidentiary disputes in advance, so that trials are not interrupted mid- course for the consideration of lengthy and complex evidentiary issues." United States v. Tokash, 282 F.3d 962, 968 (7th Cir. 2002). Still, orders in limine are preliminary and "subject to change when the case unfolds" because actual testimony may differ from a pretrial proffer. Luce v. United States, 469 U.S. 38, 41 (1984). A trial judge does not bind himself by ruling on a motion in limine and "may always change his mind during the course of a trial." Ohler v. United States, 529 U.S. 753, 758 n.3 (2000).

II. Analysis A. Plaintiffs' Motions in Limine 1. Motions 4, 5, 6, and 7: Unopposed Motions

Plaintiffs' motions in limine numbers 4 (date Plaintiffs retained counsel), 5 (reference to motions in limine), 6 (financial hardship or effect on the insurance industry), and 7 (alter ego liability/empty chair defense) are unopposed and were granted at the final pretrial conference. 2. Motions 1, 3, and 8: Setoff Issues, Settlement Negotiations, and Class Representative Fee Payments

Plaintiffs seek to exclude evidence of (1) amounts they've received that may be set off against any damages, (2) settlement negotiations, and (3) class representative fee payments. Dkt. 572 at 1–5. Setoffs against any damages the jury awards is an issue of law for the Court to decide. FDIC v. Chi. Title Ins. Co., 12 F.4th 676, 689 (7th Cir. 2021) ("Whether defendant is entitled to a setoff is a question of law."). At the final pretrial conference, the CNO Defendants agreed that setoffs are ordinarily for the Court but argued that the facts here present a unique situation with indivisible damages, so the general principle of law does not apply. The CNO Defendants provide no legal support for that argument—particularly when the damages are monetary and readily calculable—so they have not persuaded the Court that amounts Plaintiffs have received is not a question of law for the Court to decide. This motion is therefore granted and the CNO Defendants may not present evidence of (1) payments that may be set off against Plaintiffs'

damages unless that evidence is independently admissible for some other purpose, (2) settlement negotiations, and (3) class representative fee payments. Pursuant to this ruling, the CNO Defendants may not present evidence of the class settlement between Plaintiffs and CLIC and any evidence about whether Plaintiffs believed that settlement was fair and reasonable. See dkt. 582 at 2– 3. That settlement was approved as a fair and reasonable resolution of Plaintiffs' claims against only CLIC rather than of their entire claims, see dkt. 237 at 4, 26, so the CNO Defendants may not use it to limit any remaining

damages. Instead, it is merely a setoff issue for the Court. See FDIC, 12 F.4th at 689. This ruling similarly prohibits evidence that Mr. Burnett received funds from his participation in the RSA and signed an accompanying release of liability. Those are issues for the Court rather than for the jury. See id.; Larky v. Camp Livingston, Inc., 255 N.E.3d 1169, 1178 (Ind. Ct. App. 2025) ("[T]he interpretation of a written contract, including a release, is a question of law."). Even if Mr. Burnett "believed" that the RSA "constituted full compensation for

any alleged damages," dkt. 582 at 3, the measure of damages that the jury will decide is not based on his belief, but "the loss actually suffered" from not receiving "the benefit of [his] bargain." Allstate Ins. Co. v. Hammond, 759 N.E.2d 1162, 1167 (Ind. Ct. App. 2001). 3. Motion 2: Undisclosed Expert Opinions Plaintiffs seek to exclude evidence from the CNO Defendants' experts about the value of Mr. Burnett's and Dr. Camp's policies because "no defense

expert offered any policy valuations in any report." Dkt. 572 at 2–3. The CNO Defendants' expert Timothy Pfeifer, however, opined in his report that Plaintiffs suffered no damages and that several assumptions in Dr. Browne's damages calculation report are incorrect and should result in lower policy values. Dkt. 582 at 4–5 (citing Mr. Pfeifer's reports at dkt. 47-1 at 42–45 and dkt. 477-2 at 30–34). At the final pretrial conference, Plaintiffs clarified that they are seeking to exclude only evidence that goes beyond the opinions in Mr. Pfeifer's report.

This motion is limine is therefore granted in part—the CNO Defendants' experts may not offer policy valuations or methodologies for evaluating policy valuations that were not disclosed in their reports. See Fed. R. Civ. P. 37(c)(1). The motion is otherwise denied. 4. Motion 9: Testimony of Mary Jo Hudson Plaintiffs seek to exclude testimony of the CNO Defendants' expert Mary Jo Hudson because her opinions about the RSA are irrelevant. Dkt. 572 at 5– 6. The CNO Defendants respond that they intend to call Ms. Hudson "only if

she is necessary to rebut the testimony of Dr. Browne and Lisa Harpenau" related to the RSA. Dkt. 582 at 5–7. This motion therefore implicates the admissibility of evidence regarding the RSA. The jury may hear some evidence about the RSA to the extent it affected the assumptions Dr. Browne applied in his damages model. See 492-1 at 30 (explaining expense charges imposed under the RSA that Plaintiffs do not challenge). It's not clear, however, why Dr. Browne's comparisons of his model

to the Milliman RSA model used by regulators is relevant or necessary to his calculations or to Plaintiffs' breach-of-contract damages. See id. (opining that the Milliman RSA model "estimated the value of the LifeTrend book of business in terms of the discounted NPV of expected future profits or losses it would generate for Conseco under a range of scenarios."). There also should be no need for Ms. Hudson to testify regarding Dr. Browne's alternative damages methodology. See dkt. 582 at 6–7. The CNO Defendants argue that this methodology "falsely presumes that the Plaintiffs

had fully paid-up policies indefinitely," so Ms. Hudson should be able to testify that the RSA regulators did not view the Policies as paid up. Id. But that's not what Dr. Browne presumed. Dr. Browne's alternative damages model is instead based on Conseco's estimated "cost to convert each LifeTrend policy to a fully paid-up policy." Dkt. 492-1 at 34–35. And Plaintiffs confirmed at the final pretrial conference that they will not argue that the Policies were paid up, but only that Dr.

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