Insurance Law
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JOINT REQUEST FOR RULING ON OUTSTANDING ISSUE
Plaintiff and defendant’s joint request for ruling an outstanding issue.
DEFENDANT’S UNOPPOSED REQUEST FOR CLARIFICATION AND RULING
Defendant’s unopposed request for clarification and ruling states that the undersigned counsel conferred with counsel for plaintiff who does not object to the relief requested in the motion.
DEFENDANT’S RESPONSE TO PLAINTIFFS’ MOTION TO AMEND COMPLAINT TO INCLUDE A PRAYER FOR EXEMPLARY DAMAGES
Defendant’s response to plaintiff’s motion to amend complaint to include a prayer for exemplary damages.
DEFENDANT’S RESPONSE TO PLAINTIFFS’ MOTION IN LIMINE RE: DEFENDANT’S NAME INSURANCE EXCHANGE’S “OPPORTUNITY TO SETTLE”
Defendant’s response and objections to plaintiff’s motion regarding defendant’s “opportunity to settle”.
DEFENDANT’S REQUEST FOR RECONSIDERATION OF COURT’S ORDER RE: DEPOSITION
Defendant’s requests the court to reconsider objections which were upheld by Division 3 in their review of the deposition of expert.
DEFENDANT’S REPLY TO PLAINTIFFS’ RESPONSE TO FIRST MOTION IN LIMINE REGARDING HYPOTHETICAL SETTLEMENT SCENARIOS
Defendant’s reply to plaintiff’s response to the first motion regarding hypothetical settlement scenarios.
DEFENDANT’S REPLY IN SUPPORT OF SIXTH MOTION IN LIMINE REGARDING NAMES
Defendant’s reply in support of their sixth motion regarding the testimony of the expert. This motion asks the court to prevent plaintiffs from introducing evidence, testimony, or opinion from the Judge.
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.
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.
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.
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.
ANSWER AND JURY DEMAND
Defendant’s answer to Plaintiff’s complaint and defendant’s jury demand.
Plaintiff’s Motion to Strike Testimony
Plaintiff’s Motion to Strike Testimony
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.