Civil Litigation
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Previous Defendants and Settlements, MIL to Preclude Mention
Motion in limine to preclude mention of settled or dismissed defendants
No “Unavoidable Accident” Defense, Motion in Limine
Motion in limine to preclude an affirmative defense of unavoidable accident
Speculation about Medical Bill Reductions, Motion in Limine
Motion in limine to preclude speculative testimony that medical bills will be reduced
Hearsay Medical Records, Motion in Limine Precluding
MIL to Preclude Hearsay testimony reading of medical records
Plaintiff Did Not Use Insurance, Motion in Limine to Preclude Mention
Plaintiff’s MIL to preclude mention that Plaintiff did not use insurance for medical care
Defendants Motion to Reconsider Interest Rate on Promissory Note and Certificate of Conferral
DEFENDANTS MOTION PURSUANT TO C.R.C.P. 60(b) TO RECONSIDER ORDER RE: INTEREST RATE ON PROMISSORY NOTE AND CERTIFICATE OF CONFERRAL WITH C.R.C.P. 121 ‘ 1-15(8)
Response to Motion to Exclude Testimony of Non-Retained Experts
RESPONSE IN OPPOSITION TO DEFENDANT/COUNTERCLAIM PLAINTIFF MOTION TO EXCLUDE TESTIMONY OF NON-RETAINED EXPERTS
Response to Motion for Summary Judgment
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT MOTION AND BRIEF FOR SUMMARY JUDGMENT ON PLAINTIFF’S FOURTH CLAIM (BREACH OF IMPLIED WARRANTY OF MERCHANTABILITY) AND FIFTH CLAIM (BREACH OF IMPLIED WARRANTY OF FITNESS FOR A PARTICULAR PURPOSE)
Plaintiff’s Motion in Limine
PLAINTIFF’S MOTION IN LIMINE TO PRECLUDE STRIKING PLAINTIFF’S FRACK EVIDENCE OF A TRUCKING TANK
Motion for Expedited Response on Appointment of Receiver
MOTION FOR EXPEDITED RESPONSE ON APPOINTMENT OF RECEIVER
Defendant’s Response to Plaintiff’s Motion to Release Funds Held in Court Registry
DEFENDANTS’ RESPONSE TO PLAINTIFFS’ MOTION TO RELEASE FUNDS HELD IN COURT REGISTRY the Defendants respectfully ask the Court to deny the instant motion based on the authority and argument set forth in Defendants’ Motion Pursuant to C.R.C.P. 60(b) to Reconsider Order Re: Interest Rate on Promissory Note
Defendant Motion in Limine to Exclude Evidence
DEFENDANT COMPANY’S MOTION IN LIMINE TO EXCLUDE EVIDENCE OF OR REFERENCE TO ALLEGED POTENTIAL FINANCING FROM BANK OF THE WEST
Defendant Motion in Limine to Exclude Evidence of Property Damage Settlement
DEFENDANT COMPANY’S MOTION IN LIMINE TO EXCLUDE EVIDENCE OF OR REFERENCE TO BREWER’S PROPERTY DAMAGE SETTLEMENT WITH NONPARTY
Defendant Motion in Limine to Exclude Evidence of or Reference to Insurance
DEFENDANT MOTION IN LIMINE PURSUANT TO CRE 411, CRE 401, CRE 402 AND CRE 403 TO EXCLUDE EVIDENCE OF OR REFERENCE TO INSURANCE
Motion for Additional pages for Response
PLAINTIFF’S UNOPPOSED MOTION FOR ADDITIONAL PAGES FOR RESPONSE IN OPPOSITION TO DEFENDANT MOTION AND BRIEF FOR SUMMARY JUDGMENT ON PLAINTIFF’S FOURTH CLAIM (BREACH OF IMPLIED WARRANTY OF MERCHANTABILITY) AND FIFTH CLAIM (BREACH OF IMPLIED WARRANTY OF FITNESS FOR A PARTICULAR PURPOSE)