Medical Malpractice
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Speculation about Medical Bill Reductions, Motion in Limine
Motion in limine to preclude speculative testimony that medical bills will be reduced
Defendant’s Initial Rule 26 Disclosures – Personal Injury
A party must make its initial disclosures based on the information then reasonably available to it. In addition to the disclosures required by Rule 26(a)(1), a party must disclose to the other parties the identity of any witness it may use at trial to present evidence under Federal Rule of Evidence 702, 703, or 705. Appendix A to these disclosures identifies those individuals who may have discoverable information relevant to disputed facts alleged with particularity in the pleadings.
Motion to Preclude Client from Introducing Evidence or Testimony – Plaintiff was not Informed of Her Right to Undergo Testing
PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION IN LIMINE TO PRECLUDE PLAINTIFF FROM ARGUING, OR INTRODUCING EVIDENCE OR TESTIMONY, THAT PLAINTIFF WAS NOT INFORMED OF HER RIGHT ON AUGUST 1, 2012, TO UNDERGO TESTING TO DEFINITIVELY RULE OUT THE POSSIBILITY OF INFECTION
Response to Defendant’s Motion to Prohibit Plaintiff from Asking Any Medical Expert Whether the Conduct of Physicians, was “Foreseeable”
PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION IN LIMINE TO PROHIBIT PLAINTIFF FROM ASKING ANY MEDICAL EXPERT WHETHER THE CONDUCT OF , OR OTHER UCH PHYSICIANS, WAS “FORESEEABLE
Defendant’s Motion for Leaving to Conduct Ex Parte Meetings with some of Plaintiff’s Treating Health Care Providers
DEFENDANT’S MOTION FOR LEAVE TO CONDUCT EX PARTE MEETINGS WITH SOME OF PLAINTIFF’S TREATING HEALTH CARE PROVIDERS
Plaintiff’s Motion to Exclude Standard of Care Opinions by Name, M.D. Pusuant to C.R.E. 702
PLAINTIFF’S MOTION TO EXCLUDE STANDARD OF CARE OPINIONS BY NAME, M.D. PURSUANT TO C.R.E. 702
Response to Defendant’s Motion to Exclude any Evidence of Medical Expense Payments from any Collateral Source
PLAINTIFFS’ RESPONSE TO DEFENDANT’S MOTION IN LIMINE MOTION IN LIMINE TO EXCLUDE ANY EVIDENCE OF MEDICAL EXPENSE PAYMENTS FROM ANY COLLATERAL SOURCE
Plaintiff’s Motion in Limine – Medical Malpractice
PLAINTIFF’S MOTIONS IN LIMINE
A. Unopposed Motion in Limine to Preclude any Evidence or Argument Regarding the Alleged Consequences of a Damages Award in This Lawsuit or Any Other Medical Malpractice Lawsuit
B. Unopposed Motion in Limine to Preclude Any Arguments or Inferences That Plaintiff is Bringing Her Claims Simply to Win the Lottery or Otherwise Roll the Dice on Litigation
E. Motion in Limine to Preclude Any Evidence, Testimony, Argument, or Suggestion of Any Alleged Comparative Fault of Plaintiff or Failure to Mitigate Damages by Plaintiff.
A. Motion in Limine to preclude any expert witness from offering opinions or testimony outside the scope of their previously disclosed opinions.
Defendat’s Combined Motions in Limine
DEFENDANT’S COMBINED MOTIONS IN LIMINE
Plaintiff’s Post-Trial Motion to Exceed the $1,000,000.00 Cap
PLAINTIFF’S POST-TRIAL MOTION TO EXCEED THE $1,000,000.00 CAP CONTAINED IN C.R.S. § 13-64-302(1)(b)
Defendant’s Response to Plaintiff’s Motion on Admissibilty of Insurance for Purposes of Establishing Bias
DEFENDANT’S RESPONSE TO PLAINTIFF’S TRIAL BRIEF (MOTION IN LIMINE) ON ADMISSIBILITY OF INSURANCE FOR PURPOSES OF ESTABLISHING BIAS
Plaintiff’s Response to Motion for New Trial – Medical Malpractice
PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION FOR NEW TRIAL
Motion to Preclude Expert From Offering Testimony Outside the Scope of Previously Disclosed Opinions
PLAINTIFF’S SUPPLEMENT TO MOTION IN LIMINE TO PRECLUDE ANY EXPERT FROM OFFERING OPINIONS OR TESTIMONY OUTSIDE THE SCOPE OF THEIR PREVIOUSLY DISCLOSED OPINIONS
Response to Defendant’s Motion To Preclude Plaintiff From Asking Any Expert…
PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION IN LIMINE TO PRECLUDE PLAINTIFF FROM ASKING ANY EXPERT ON EITHER SIDE WHETHER WERE “NEGLIGENT”