Civil Litigation
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Brief in Support of Particular Social Group for Asylum
Brief arguing that certain gang based and domestic sexual violence based claims still qualify as a particular social group membership for purposes of asylum post Matter of A-B-. Also argues that certain conclusions reached in Matter of A-B- are flawed and contradict current caselaw.
Defendant Jury Instruction
Civil case Jury instruction with Mitigation of damages Defense
PLAINTIFFS’ RESPONSE TO DEFENDANT’S MOTION FOR CLARIFICATION OF ORDER RE: HYPOTHETICAL SETTLEMENT SCENARIOS
PLAINTIFFS’ RESPONSE TO DEFENDANT’S MOTION FOR CLARIFICATION OF ORDER RE: HYPOTHETICAL SETTLEMENT SCENARIOS
PLAINTIFFS’ RESPONSE IN OPPOSITION TO DEFENDANT’S THIRD MOTION IN LIMINE REGARDING RIGHTS VERSUS DUTIES
Plaintiff’s response in opposition to defendant’s third motion in limine regarding rights versus duties.
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S SIXTH MOTION IN LIMINE REGARDING
Plaintiff’s response to defendant’s sixth motion in limine regarding expert.
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S SECOND MOTION IN LIMINE REGARDING PEV AND RESERVE INFORMATION
| PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S SECOND MOTION IN LIMINE REGARDING PEV AND RESERVE INFORMATION. |
PLAINTIFFS’ RESPONSE IN OPPOSITION TO DEFENDANT’S FOURTH MOTION IN LIMINE REGARDING
Plaintiff’s response in opposition to defendant’s fourth motion in limine regarding expert.
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S FIRST MOTION IN LIMINE REGARDING HYPOTHETICAL SETTLEMENT SCENARIOS
Plaintiff’s response in opposition to defendant’s first motion in limine regarding hypothetical settlement scenarios.
PLAINTIFFS’ RESPONSE TO DEFENDANT’S FIFTH MOTION IN LIMINE REGARDING MILLER VALUATIONS
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PLAINTIFFS’ RESPONSE TO DEFENDANT’S FIFTH MOTION IN LIMINE REGARDING MILLER VALUATIONS. |
PLAINTIFFS’ REPLY IN SUPPORT OF MOTION TO AMEND COMPLAINT TO INCLUDE A PRAYER FOR EXEMPLARY DAMAGES
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PLAINTIFFS’ REPLY IN SUPPORT OF MOTION TO AMEND COMPLAINT TO INCLUDE A PRAYER FOR EXEMPLARY DAMAGES |
PLAINTIFFS’ REPLY IN SUPPORT OF MOTION IN LIMINE RE: DEFENDANT’S “OPPORTUNITY TO SETTLE”
Plaintiff’s reply in support of motion in limine RE: defendant’s “opportunity to settle”.
PLAINTIFFS PROPOSED JURY INSTRUCTIONS
Plaintiff’s proposed jury instructions.
PLAINTIFFS’ MOTION TO AMEND COMPLAINT TO INCLUDE A PRAYER FOR EXEMPLARY DAMAGES
Plaintiff’s motion that requests that the court enter an order permitting them to amend their complaint to include a prayer for exemplary damages.
PLAINTIFFS’ MOTION IN LIMINE RE: DEFENDANT’S “OPPORTUNITY TO SETTLE”
Plaintiff’s motion in limine Re: Defendant’s “opportunity to settle”
PLAINTIFFS’ MOTION FOR LEAVE TO FILE RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION TO BIFURCATE TRIAL OF LIABILITY AND DAMAGES ISSUES OUT OF TIME
Plaintiff’s motion for leave to file response in opposition to defendant’s motion to bifurcate trial of liability and damages issues out of time.