Civil Litigation
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Defendant’s Unopposed Motion for an Enlargement of Time to Reply in Support of its Motion to Dismiss
Defendant’s motion to pursuant to the provisions of Rule 6(b) of the Colorado Rules of Civil Procedure to enlarge the specified period for replying to Plaintiffs’ Response to Motion to Dismiss by two weeks
Defendants’ Response to New York Attorney’s Rule 221 Motion
Defendant’s response to New York attorney’s rule 221 motion requesting permission to appear as counsel for Plaintiffs in this case.Â
Defendant’s Name’s Response in Opposition to Plaintiffs’ Motion to Set Aside Dismissals or Alternatively Leave to File a Third Amended Complaint and Jury Demand
DEFENDANT’S NAME’S RESPONSE IN OPPOSITION TO PLAINTIFFS’ MOTION TO SET ASIDE DISMISSALS OR ALTERNATIVELY LEAVE TO FILE A THIRD AMENDED COMPLAINT AND JURY DEMAND
Defendants’ Trial Brief – Personal Injury
A trial brief sets forth the facts, evidence, and legal arguments the party intends to present at trial. A trial brief includes issue, which identify the issue raised by the facts of the client’s case. Rule , which identify the law(s) that controls the issue(s). Analysis, which explains how the rule of law apply to the issue(s). Conclusion, which is a summary of the legal analysis.
Plaintiffs’ Motion in Limine to Admit into Evidence a Copy of the Notebook Written, Kept and Maintained by Shooter
PLAINTIFFS’ MOTION IN LIMINE TO ADMIT INTO EVIDENCE A COPY OF THE NOTEBOOK WRITTEN, KEPT AND MAINTAINED BY SHOOTER
Plaintiffs’ Motion in Limine to Preclude Defendants from Referencing Legally Incorrect Standard of Foreseeability Under Colorado’s Premises Liability Statue
PLAINTIFFS’ MOTION IN LIMINE TO PRECLUDE DEFENDANTS FROM REFERENCING LEGALLY INCORRECT STANDARD OF FORESEEABILITY UNDER COLORADO’S PREMISES LIABILITY STATUTE
Plaintiffs’ Motion in Limine to Preclude Defendants from Referencing Movie Theater Industry Security Standard, Protocols or Practices
PLAINTIFFS’ MOTION IN LIMINE TO PRECLUDE DEFENDANTS FROM REFERENCING MOVIE THEATER INDUSTRY SECURITY STANDARDS, PROTOCOLS OR PRACTICES
Plaintiffs’ Motion in Limine to Preclude Defendant from Referencing Other Specific Mass Casualty Events
Plaintiff’s motion for Defendants, their counsel and their witnesses from making or espousing statements, opinions or arguments at trial concerning, pertaining to or relating to specific other mass casualty events
Plaintiffs’ Motion in Limine to Preclude Defendants From Referencing the Biographical Backgrounds of Counsel
PLAINTIFFS’ MOTION IN LIMINE TO PRECLUDE DEFENDANTS FROM REFERENCING THE BIOGRAPHICAL BACKGROUNDS OF COUNSEL
Defendants’ Combined Motions in Limine
Defendants motion to exclude from trial testimony and evidence of (1) expiration of the statute of limitations against; (2) Defendants’ budget, profit, and bonus policies; (3) irrelevant previous crimes; (4) Defendants’ firearm policy; (5) subsequent remedial measures; (6) Defendants’ alleged failure to produce evidence; (7) Plaintiffs’ injuries; (8) insurance coverage; and (9) placing the jury into the Plaintiffs’ position.
Response to Plaintiffs’ Motion to Exclude Defendants’ Experts
 Plaintiff’s motion to limit the testimony of four of the defendants’ experts.Â
Plaintiffs’ Notice of Partial Withdrawal of Expert Disclosures Pursuant to C.R.C.P. 26(a)(2) and Response to Defendants’ Motion to Exclude Plaintiffs’ Experts Under Colo. R. Evid. 702
PLAINTIFFS’ NOTICE OF PARTIAL WITHDRAWAL OF EXPERT DISCLOSURES PURSUANT TO C.R.C.P. 26(a)(2) AND RESPONSE TO DEFENDANTS’ MOTION TO EXCLUDE PLAINTIFFS’ EXPERTS UNDER COLO. R. EVID. 702
Soudani Plaintiffs’ and Defendants’ Joint Brief on Jury Questionnaires
Plaintiffs and Defendants submit this brief on the Court’s ability to permit counsel to remove jury questionnaires from the courthouse grounds.
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Plaintiffs’ Motion to Exclude Defendants’ Designated Experts Pursuant to C.R.E. 702
Defendant’s motion for an Order excluding at the trial of this matter the testimony of four purported experts proffered by Defendants