DEFENDANT’S COMBINED REPLY IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT, MOTION FOR DETERMINATION OF LAW, AND MOTION FOR PARTIAL SUMMARY JUDGMENT AS TO THE CONDUCT
Defendant’s combined reply in support of motions for summary judgment, motion for determination of law, and motion for partial summary judgement as to the conduct of a person.Â
DEFENDANT’S EMERGENCY MOTION FOR TELEPHONIC HEARING
Defendant’s counsel certifies that he has attempted to contact plaintiff’s counsel several times and received no response prior to filing this motion. Defendant filed a motion in Limine regarding hypothetical settlement scenarios.Â
DEFENDANT’S FIFTH MOTION IN LIMINE REGARDING NAME VALUATIONS
Defendant’s fifth motion in limine regarding valuations performed by a person that is an expert witness for plaintiff.Â
DEFENDANT’S FIRST MOTION IN LIMINE REGARDING HYPOTHETICAL SETTLEMENT SCENARIOS
Defendant’s first motion in limine regarding the hypothetical settlement scenarios that states the pursuant to CRCP 121, counsel certifies conferral with counsel for plaintiff who objects to the relief requested.Â
DEFENDANT’S FOURTH MOTION IN LIMINE REGARDING NAME
Defendant’s fourth motion in limine regarding conduct, advice, actions or inaction of plaintiff’s witness.Â
DEFENDANT’S MOTION FOR CLARIFICATION REGARDING THE COURT’S ORDER ON ITS FIRST MOTION IN LIMINE REGARDING HYPOTHETICAL SETTLEMENT SCENARIOS
Defendant’s motion for clarification regarding the court’s order on defendant’s first motion in limine regarding the hypothetical settlement scenarios.Â
DEFENDANT’S MOTION FOR DETERMINATION OF LAW
Defendant’s pursuant to C.R.C.P 56, makes the motion for determination of law: pursuant to C.R.C.P. 121, undersigned counsel certifies conferral with counsel for plaintiff who objects to the relief requested in this motion.Â
DEFENDANT’S MOTION FOR PARTIAL SUMMARY JUDGMENT AS TO THE CONDUCT OF NAME
Defendant’s motion for partial summary judgment, as to the conduct of plaintiff’s witness, follows the pursuant to C.R.C.P 121, counsel certifies conferral with counsel for plaintiff who objects to the relief requested in this motion. Â
DEFENDANT’S MOTION FOR SUMMARY JUDGMENT
Defendant’s pursuant to C.R.C.P. 56, makes the following motion for summary judgement: pursuant to C.R.C.P 121, undersigned counsel certifies conferral with counsel for plaintiff who objects to the relief requested in this motion.Â
DEFENDANT’S MOTIONS FOR DIRECTED VERDICT
Defendant’s motion for directed verdict under C.R.C.P 50.
DEFENDANT’S PROPOSED JURY INSTRUCTIONS
DEFENDANT’S PROPOSED JURY INSTRUCTIONS
DEFENDANT’S REPLY IN SUPPORT OF FIFTH MOTION IN LIMINE REGARDING MILLER VALUATIONS
Defendant’s motion to ask the court to prevent plaintiff’s from introducing the testimony from their expert witness.Â
DEFENDANT’S REPLY IN SUPPORT OF FOURTH MOTION IN LIMINE REGARDING ATTORNEY’S NAME
Defendant’s reply in support motion regarding conduct, advice, actions or inaction of the attorney.Â
DEFENDANT’S REPLY IN SUPPORT OF MOTION FOR CLARIFICATION OF ORDER ON FIRST MOTION IN LIMINE REGARDING HYPOTHETICAL SETTLEMENT SCENARIOS
Defendant submits a reply in support of its motion for clarification of the order on defendant’s first motion regarding hypothetical settlement scenarios.Â
DEFENDANT’S REPLY IN SUPPORT OF SECOND MOTION IN LIMINE REGARDING PEV AND RESERVE INFORMATION
Defendant’s reply in support of second motion regarding the prevention of plaintiff from introducing evidence, testimony, or argument regarding the pure exposure value (PEV) or reserve information for the expert witness.Â