Civil Litigation
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PLAINTIFFS PROPOSED JURY INSTRUCTIONS
Plaintiff’s proposed jury instructions.
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.
PLAINTIFFS’ MOTION FOR LEAVE TO FILE COMBINED RESPONSE TO DEFENDANT’S RULE 56 MOTIONS OUT OF TIME
Plaintiff’s motion to request that the court permit them to file their combined response to defendant’s rule 56 motions out of time.
PLAINTIFF’S FINAL MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT
Plaintiff requests that the court gran an extension of time to file their response to defendant’s motion for summary judgment.
PLAINTIFFS’ FINAL LIST OF REMAINING OBJECTIONS FROM PRESERVATION DEPOSITION OF — THAT REQUIRE RULINGS
Plaintiff states their final list of remaining objections from preservation deposition of expert that require rulings.
PLAINTIFFS’ COMBINED RESPONSE TO DEFENDANT’S RULE 56 MOTIONS
PLAINTIFFS’ COMBINED RESPONSE TO DEFENDANT’S RULE 56 MOTIONS
PLAINTIFFS’ ADDITIONAL MOTION FOR ONE-DAY EXTENSION OF TIME
Plaintiff’s additional motion for one-day extension of time to file responses to defendant’s motion for summary judgement, motion for determination of law and motion for partial summary judgment as to the conduct of expert.
MOTION TO BIFURCATE TRIAL OF LIABILITY AND DAMAGES ISSUES
Defendant’s motion to move pursuant to C.R.C.P 42 to bifurcate the trial of liability issues from the trial of damages issues.
JOINT REQUEST FOR RULING ON OUTSTANDING ISSUE
Plaintiff and defendant’s joint request for ruling an outstanding issue.
DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME FOR SUBMISSION OF REPLY IN SUPPORT OF MOTION FOR CLARIFICATION
Defendant’s unopposed motion for extension of time to provide a reply in support of motion for clarification.
DEFENDANT’S THIRD MOTION IN LIMINE REGARDING RIGHTS VERSUS DUTIES
Defendant’s third motion in limine regarding rights versus duties states that pursuant to CRCP 121, counsel certifies conferral with counsel for plaintiff who object to the relief requested.
DEFENDANT’S SIXTH MOTION IN LIMINE REGARDING NAME
Defendant’s sixth motion in limine regarding the testimony of expert witness.
DEFENDANT’S SECOND MOTION IN LIMINE REGARDING PEV AND RESERVE INFORMATION
Defendant’s second motion regarding PEV or reserve information.