Civil Litigation
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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
Motion to Confess Judgment on Promissory Note, Dismiss all Related Claims, and Request for Forthwith Ruling
MOTION TO CONFESS JUDGMENT ON PROMISSORY NOTE AND DISMISS ALL RELATED CLAIMS AND REQUEST FOR FORTHWITH RULING 2. Plaintiffs therefore respectfully request that the Court dismiss with prejudice all claims related to the Note, including Plaintiffs’ claim for Negligent Misrepresentation against Defendant– Water Shares (Plaintiffs’ Third Amended Complaint, Fifth Claim for Relief) and the Defendants’ Counterclaim for Breach of Contract under the terms of the Note (Defendants’ Answer, Jury Demand, and Counterclaim, First and Second Claims for Relief in the Counterclaim).
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.
Plaintiff’s Motion to Restrict Access
PLAINTIFF’S MOTION TO RESTRICT ACCESS to Plaintiff’s attorney medical records.
Plaintiff’s Motion to Introduce Summaries into Evidence at Trial
PLAINTIFF’S MOTION TO INTRODUCE SUMMARIES INTO EVIDENCE AT TRIAL
Plaintiff’s Motion to Compel Production of Documents and for Expedited Hearing
PLAINTIFF’S MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND FOR EXPEDITED HEARING in an employment Title vII case
Plaintiff’s Motion for Evidentiary Hearing on Back Pay
PLAINTIFF’S MOTION FOR EVIDENTIARY HEARING ON BACK PAY after receiving a judgment on title VII case
Plaintiff’s Motion for Attorney Fees
After receiving a judgment in employment case Plaintiff is requesting attorney fees as prevailing party
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 Post-Trial Motion to Reduce Jury Verdict in Accordance with HCAA’S CAPS
DEFENDANT’S POST-TRIAL MOTION TO REDUCE THE JURY VERDICT IN ACCORDANCE WITH THE HCAA’S CAPS
Plaintiff’s Motion to Strike Defendant’s Expert Disclosures of M.D.
PLAINTIFF’S MOTION TO STRIKE DEFENDANT’S FOURTH SUPPLEMENTAL C.R.C.P. 26(a)(2) EXPERT DISCLOSURES OF , M.D.
Motion to Vacate Bench Warrant
MOTION TO VACATE BENCH WARRANT for a civil show cause order
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
Plaintiff’s Motion to Strike Certain Opinions of Defendant – Malpractice
PLAINTIFF’S MOTION TO STRIKE CERTAIN OPINIONS OF DEFENDANT,
AND NAME