Civil Litigation
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DEFENDANT’S RESPONSE TO PLAINTIFFS’ MOTION TO AMEND COMPLAINT TO INCLUDE A PRAYER FOR EXEMPLARY DAMAGES
Defendant’s response to plaintiff’s motion to amend complaint to include a prayer for exemplary damages.Â
DEFENDANT’S REQUEST FOR RECONSIDERATION OF COURT’S ORDER RE: DEPOSITION
Defendant’s requests the court to reconsider objections which were upheld by Division 3 in their review of the deposition of expert.Â
DEFENDANT’S REPLY TO PLAINTIFFS’ RESPONSE TO FIRST MOTION IN LIMINE REGARDING HYPOTHETICAL SETTLEMENT SCENARIOS
Defendant’s reply to plaintiff’s response to the first motion regarding hypothetical settlement scenarios.Â
DEFENDANT’S REPLY IN SUPPORT OF THIRD MOTION IN LIMINE REGARDING RIGHTS VERSUS DUTIES
Defendant’s reply in support of third motion regarding rights versus duties owed by defendant.Â
DEFENDANT’S REPLY IN SUPPORT OF SIXTH MOTION IN LIMINE REGARDING NAMES
Defendant’s reply in support of their sixth motion regarding the testimony of the expert. This motion asks the court to prevent plaintiffs from introducing evidence, testimony, or opinion from the Judge.
DEFENDANT’S REPLY IN SUPPORT OF SECOND MOTION IN LIMINE REGARDING PEV AND RESERVE INFORMATION
Defendant’s reply in support of second motion regarding the prevention of plaintiff from introducing evidence, testimony, or argument regarding the pure exposure value (PEV) or reserve information for the expert witness.Â
DEFENDANT’S REPLY IN SUPPORT OF FOURTH MOTION IN LIMINE REGARDING ATTORNEY’S NAME
Defendant’s reply in support motion regarding conduct, advice, actions or inaction of the attorney.Â
DEFENDANT’S REPLY IN SUPPORT OF FIFTH MOTION IN LIMINE REGARDING MILLER VALUATIONS
Defendant’s motion to ask the court to prevent plaintiff’s from introducing the testimony from their expert witness.Â
DEFENDANT’S PROPOSED JURY INSTRUCTIONS
DEFENDANT’S PROPOSED JURY INSTRUCTIONS
DEFENDANT’S MOTION FOR SUMMARY JUDGMENT
Defendant’s pursuant to C.R.C.P. 56, makes the following motion for summary judgement: pursuant to C.R.C.P 121, undersigned counsel certifies conferral with counsel for plaintiff who objects to the relief requested in this motion.Â
DEFENDANT’S MOTION FOR PARTIAL SUMMARY JUDGMENT AS TO THE CONDUCT OF NAME
Defendant’s motion for partial summary judgment, as to the conduct of plaintiff’s witness, follows the pursuant to C.R.C.P 121, counsel certifies conferral with counsel for plaintiff who objects to the relief requested in this motion. Â
DEFENDANT’S MOTION FOR DETERMINATION OF LAW
Defendant’s pursuant to C.R.C.P 56, makes the motion for determination of law: pursuant to C.R.C.P. 121, undersigned counsel certifies conferral with counsel for plaintiff who objects to the relief requested in this motion.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 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 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