Insurance Law
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Answered filed for uninsured motorist
An answered filed by insurance company in Colorado Federal District Court
Declaratory Judgment Not to Defend – Insurance
Insurance company filing a declaratory judgement order indicating no duty to defend
Letter to Life Insurance Company for Claim
A sample letter to send to life insurance company by a beneficiary of the life insurance policy. I recommend sending this out shortly after receiving the death certificate. Make sure to include the death certificate, as well.
DEFENDANT’S PROPOSED JURY INSTRUCTIONS
DEFENDANT’S PROPOSED JURY INSTRUCTIONS
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
PLAINTIFFS’ FINAL LIST OF REMAINING OBJECTIONS FROM PRESERVATION DEPOSITION OF — THAT REQUIRE RULINGS
Plaintiff states their final list of remaining objections from preservation deposition of expert that require rulings.Â
PLAINTIFFS PROPOSED JURY INSTRUCTIONS
Plaintiff’s proposed jury instructions.Â
Wrongful Death Complaint – Workers Compensation
Document filing a complaint against a defendant who’s action caused a person’s death, either by negligence or intentionally. Wrongful death documents are filed by a representative of the deceased, typically a family member.
Complaint and Jury Demand (bad faith)
Complaint and Jury Demand (bad faith)
Complaint and Jury Demand (personal injury)
Complaint and Jury Demand (personal injury)
Response Brief to Motion for Summary Judgment
Insurance interpleader case where there was a dispute as to who gets a life insurance policy. I represented the name beneficiary and the other party was the descendants two daughters. The daughters claimed they were entitled to insurance proceeds because he was required to pay child support. This my response to their motion for summary judgment.
Plaintiff’s Motion to Strike Testimony
Plaintiff’s Motion to Strike Testimony
ANSWER AND JURY DEMAND
Defendant’s answer to Plaintiff’s complaint and defendant’s jury demand.Â
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 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