Civil Litigation
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Motion to Confess Judgment on Promissory Note, Dismiss all Related Claims, and Request for Forthwith Ruling
MOTION TO CONFESS JUDGMENT ON PROMISSORY NOTE AND DISMISS ALL RELATED CLAIMS AND REQUEST FOR FORTHWITH RULING 2. Plaintiffs therefore respectfully request that the Court dismiss with prejudice all claims related to the Note, including Plaintiffs’ claim for Negligent Misrepresentation against Defendant– Water Shares (Plaintiffs’ Third Amended Complaint, Fifth Claim for Relief) and the Defendants’ Counterclaim for Breach of Contract under the terms of the Note (Defendants’ Answer, Jury Demand, and Counterclaim, First and Second Claims for Relief in the Counterclaim).
Response to Defendant’s Motion to Exclude any Evidence of Medical Expense Payments from any Collateral Source
PLAINTIFFS’ RESPONSE TO DEFENDANT’S MOTION IN LIMINE MOTION IN LIMINE TO EXCLUDE ANY EVIDENCE OF MEDICAL EXPENSE PAYMENTS FROM ANY COLLATERAL SOURCE
Response to Plaintiff’s Shreck Motion to Preclude Testimony of Doctor
Defendant RESPONSE TO PLAINTIFFS’ SHRECK MOTION IN LIMINE TO PRECLUDE THE TESTIMONY OF DR. A
Plaintiff’s Motion in Limine – Medical Malpractice
PLAINTIFF’S MOTIONS IN LIMINE
A. Unopposed Motion in Limine to Preclude any Evidence or Argument Regarding the Alleged Consequences of a Damages Award in This Lawsuit or Any Other Medical Malpractice Lawsuit
B. Unopposed Motion in Limine to Preclude Any Arguments or Inferences That Plaintiff is Bringing Her Claims Simply to Win the Lottery or Otherwise Roll the Dice on Litigation
E. Motion in Limine to Preclude Any Evidence, Testimony, Argument, or Suggestion of Any Alleged Comparative Fault of Plaintiff or Failure to Mitigate Damages by Plaintiff.
A. Motion in Limine to preclude any expert witness from offering opinions or testimony outside the scope of their previously disclosed opinions.
Plaintiff’s Motion to Restrict Access
PLAINTIFF’S MOTION TO RESTRICT ACCESS to Plaintiff’s attorney medical records.
Plaintiff’s Motion to Introduce Summaries into Evidence at Trial
PLAINTIFF’S MOTION TO INTRODUCE SUMMARIES INTO EVIDENCE AT TRIAL
Plaintiff’s Motion to Compel Production of Documents and for Expedited Hearing
PLAINTIFF’S MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND FOR EXPEDITED HEARING in an employment Title vII case
Plaintiff’s Motion for Evidentiary Hearing on Back Pay
PLAINTIFF’S MOTION FOR EVIDENTIARY HEARING ON BACK PAY after receiving a judgment on title VII case
Plaintiff’s Motion for Attorney Fees
After receiving a judgment in employment case Plaintiff is requesting attorney fees as prevailing party
Defendat’s Combined Motions in Limine
DEFENDANT’S COMBINED MOTIONS IN LIMINE
Discrimination complaint
Title VII complaint with Wrongful Discharge in Violation of Public Policy as set forth in the Colorado Anti-Discrimination Act
Defendant’s Response in Opposition to Plaintiff’s Motion to Strike Defendant’s affirmative Defense of Nonparty at fault
DEFENDANT’S RESPONSE IN OPPOSITION TO PLAINTIFF’S MOTION TO STRIKE DEFENDANT’S AFFIRMATIVE DEFENSE OF NONPARTY AT FAULT
Plaintiff’s Trial Brief on Admissabilty of Insurance for Purposes of Establishing Bias
PLAINTIFF’S TRIAL BRIEF ON ADMISSABILITIY OF INSURANCE FOR PURPOSES OF ESTABLISHING BIAS
First Supplamental Response to Plaintiff’s Motion to Strike Defendant’s Affirmative Defense
DEFENDANT’S FIRST SUPPLEMENTAL RESPONSE TO PLAINTIFF’S SUPPLEMENT TO MOTION TO STRIKE DEFENDANT’S AFFIRMATIVE DEFENSE OF NONPARTY AT FAULT AND TO PRECLUDE INADMISSIBLE EVIDENCE CONCERNING ALLEGED NEGLIGENCE OR FAULT