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Defendants’ Response to New York Attorney’s Rule 221 Motion
Defendant’s response to New York attorney’s rule 221 motion requesting permission to appear as counsel for Plaintiffs in this case.Â
Defendant’s Unopposed Motion for an Enlargement of Time to Reply in Support of its Motion to Dismiss
Defendant’s motion to pursuant to the provisions of Rule 6(b) of the Colorado Rules of Civil Procedure to enlarge the specified period for replying to Plaintiffs’ Response to Motion to Dismiss by two weeks
Defendants’ Joint Unopposed Motion for an Enlargement of Time to Designate Non-parties at Fault Pursuant to C.R.S. § 13-21-111.5 and Request for Ruling Forthwith
DEFENDANTS’ JOINT UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO DESIGNATE NONPARTIES AT FAULT PURSUANT TO C.R.S. § 13-21-111.5 AND REQUEST FOR RULING FORTHWITH
First Amended Complaint and Jury Demand
Plaintiffs pursuant to C.R.C.P. 25(a), respectfully submit the following First Amended Complaint and Jury Trial Demand.
Motion for Leave to File Second Amended Complaint and Jury Demand
Plaintiff’s motion for leave to file second amended complaint and jury demand.Â
Motion to Consolidate – Personal Injury
A motion to consolidate is a motion which seeks to combine two cases into one proceeding. It may be granted if the cases involve common questions of law or fact to be resolved. When the cases involve similar or related questions to be decided, the court may consolidate the cases in order to promote the efficient use of judicial resources.
Motion to Set Aside Dismissals or Alternatively Leave to File Third Amended Complaint and Jury Demand
Motion to set aside dismissals or alternatively leave to file third amended complaint and jury demand.
Plaintiffs’ Response to Motion to Dismiss by the Retail Property Trust and Simon Entities
Plaintiffs’ response to motion to dismiss by the retail property trust and Simon entities.
Reply in Support of Motion for Pro Hac Vice Admission
Plaintiff’s reply in support of defendant’s motion for pro hac vice admission.Â
Defendant’s Motion to Dismiss
Defendant’s motion to dismiss the Second Amended Complaint on the ground that it fails to state a claim upon which relief can be granted.Â
ANSWER AND JURY DEMAND
Defendant’s answer to Plaintiff’s complaint and defendant’s jury demand.Â
DEFENDANT’S COMBINED REPLY IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT, MOTION FOR DETERMINATION OF LAW, AND MOTION FOR PARTIAL SUMMARY JUDGMENT AS TO THE CONDUCT
Defendant’s combined reply in support of motions for summary judgment, motion for determination of law, and motion for partial summary judgement as to the conduct of a person.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
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 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