Civil Litigation
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Motion for Order Authorizing Production of Records Pursuant to Colo. R. CIV. P. 45(c)(2)(B) and Request for Expedited Ruling
MOTION FOR ORDER AUTHORIZING PRODUCTION OF RECORDS PURSUANT TO COLO. R. CIV. P. 45(c)(2)(B) AND REQUEST FOR EXPEDITED RULING
Plaintiffs’ Brief in Opposition to a Stay of Litigation
Plaintiff’s brief in opposition to a stay of litigation, submit this brief in opposition to a stay proceedings.Â
Defendants’ Brief Regarding a Partial Stay
DEFENDANTS’ BRIEF REGARDING A PARTIAL STAY.
Plaintiffs’ Brief on the Issue of Bifurcation
Plaintiff provides the instant brief on the issue of whether bifurcation of the liability and damages phases of the trial of this action is necessary. Bifurcation is a judge’s ability in law to divide a trial into two parts so as to render a judgment on a set of legal issues without looking at all aspects. In a bifurcated case, the issues of liability and damages are decided separately. The trier of fact will only decide the issue of liability at the first trial. If the defendant is not found to be liable, then there will be no damages trial.
Defendants’ Motion for a Protective Order to Sequence Discovery on Liability
A motion for protective order refers to a party’s request that the court protect it from potentially abusive action by the other party. Such a request is often made in relation to discovery, as when one party seeks discovery of the other party’s trade secrets. A protective order from discovery protects the person who would otherwise have to provide discovery (e.g. answer interrogatories, answer deposition questions on a subject, provide documents responsive to a request for production of documents, to allow someone to inspect premises, or to participate in a forensic medical.
Unopposed Motion for Leave to File First Amended Complaint and Jury Demand
Plaintiff’s unopposed motion for leave to file first amended complaint and jury demand.
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Plaintiffs’ Opposition to Defendants’ Motion to Coordinate Depositions
Defendant’s motion to have Plaintiffs action to coordinate the depositions of defendant’s employees with separate federal court cases all to the prejudice of plaintiffs herein.Â
Defendants’ Motion to Coordinate Depositions
Defendant’s motion to move to coordinate the depositions between the related cases currently pending in two district courts.Â
Defendants’ Notice of Removal – Personal Injury
Defendant’s notice of removal to remove the instant case to the United States District Court for the District of Colorado. A notice of removal is signed by the defendants and filed in federal court to begin the process of transferring the civil action from state court to federal court. Promptly after the filing of such notice of removal of a civil action the defendant or defendants shall give written notice thereof to all adverse parties and shall file a copy of the notice with the clerk of such State court, which shall effect the removal and the State court shall proceed no further.
Defendants’ Joinder in Support of Defendants’ Names’ Motion for Summary Judgement and Request for Forthwith Ruling
DEFENDANTS’ JOINDER IN SUPPORT OF DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT AND REQUEST FOR FORTHWITH RULING.Â
Plaintiffs’ Response to Motion to Dismiss by the Retail Property Trust and Simon Entities
Plaintiff’s Motion to Dismiss Plaintiffs’ Second Amended Complaint by the Retail Property Trust and Simon entities.Â
Plaintiffs’ Opposition to Motion to Dismiss Defendants
Plaintiff’s opposition to defendant’s motion to dismiss the complaint.
Defendants’ Motion to Dismiss
Defendant’s motion to dismiss people from the lawsuit on the grounds that the complaint fails to state a claim upon which relief can be granted.