Civil Litigation
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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 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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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.