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Defendant’s trial brief
Defendant’s trial brief addresses the direction to the parties on the which will be provided to the jury including whether Soriano is now the law of the case and whether the defendant can challenge the reasonableness of the arbitration award.
Defendant’s Trial Brief and Objection to Plaintiff’s Proposed Jury Instructions and Findings of Fact
Defendant’s Trial Brief and Objection to Plaintiff’s Proposed Jury Instructions and Findings of Fact
Defendant’s Unopposed Motion for Enlargement of Time to Respond to Plaintiff’s Partial Motion for Summary Judgment
Defendant’s Unopposed Motion for Enlargement of Time to Respond to Plaintiff’s Partial Motion for Summary Judgment
Defendant’s Unopposed Motion for Leave to Exceed Page Limit
Defendant’s Unopposed Motion for Leave to Exceed Page Limit
Defendant’s Answer to Plaintiff’s Complaint and Jury Demand
DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT AND JURY DEMAND to negligence arguing comparative negligence
Defendant’s Answer, Cross-Claim and Jury Demand
DEFENDANT’S ANSWER, CROSS-CLAIM AND JURY DEMAND cross claim for breach of contract and promissory estoppel
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 EMERGENCY MOTION FOR TELEPHONIC HEARING
Defendant’s counsel certifies that he has attempted to contact plaintiff’s counsel several times and received no response prior to filing this motion. Defendant filed a motion in Limine regarding hypothetical settlement scenarios.Â
DEFENDANT’S FIFTH MOTION IN LIMINE REGARDING NAME VALUATIONS
Defendant’s fifth motion in limine regarding valuations performed by a person that is an expert witness for plaintiff.Â
DEFENDANT’S FIRST MOTION IN LIMINE REGARDING HYPOTHETICAL SETTLEMENT SCENARIOS
Defendant’s first motion in limine regarding the hypothetical settlement scenarios that states the pursuant to CRCP 121, counsel certifies conferral with counsel for plaintiff who objects to the relief requested.Â
DEFENDANT’S FOURTH MOTION IN LIMINE REGARDING NAME
Defendant’s fourth motion in limine regarding conduct, advice, actions or inaction of plaintiff’s witness.Â
DEFENDANT’S MEMORANDUM IN SUPPORT OF ITS MOTION TO DISMISS
PLAINTIFF sued DEFENDANT for breach of contract and misappropriation of trade secrets. PLAINTIFF does not, however, allege that DEFENDANT actually breached the contract nor does it have any evidence whatsoever that he has misappropriated trade secrets.
Defendant’s Motion for Attorney Fees and Costs
DEFENDANTS’ MOTION FOR ATTORNEY FEES AND COSTS
DEFENDANT’S MOTION FOR CLARIFICATION REGARDING THE COURT’S ORDER ON ITS FIRST MOTION IN LIMINE REGARDING HYPOTHETICAL SETTLEMENT SCENARIOS
Defendant’s motion for clarification regarding the court’s order on defendant’s first motion in limine regarding the hypothetical settlement scenarios.Â