Civil Litigation
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Defendant/Counterclaimant’s Response to Plaintiff’s Motion & Brief for Summary Judgment
Defendant/Counterclaimant’s Response to Plaintiff’s Motion; Brief for Summary Judgment and Motion to Strike and Motion for Attorney’s Fees and Costs
Motion for Brief for Summary Judgment and Dismissal of Defendant Foulk’s Second Counterclaim
MOTION & BRIEF FOR SUMMARY JUDGMENT AND DISMISSAL OF DEFENDANT FOULK’S SECOND COUNTERCLAIM: “(Retaliation—Title VII—42 U.S.C. § 2000e-2)” MOTION TO STRIKE RELATED SECOND COUNTERCLAIM AVERMENTS
C.R.C.P. 12(f) MOTION FOR ATTORNEY FEES & COSTS C.R.S. §§ 13-17-102, 13-16-104, and C.R.C.P. 11
Reply to Defendant’s Counterclaims
REPLY TO DEFENDANT’S COUNTERCLAIMS
Answer and Counterclaims
Answer and counterclaim for First Counterclaim (Title VII- Hostile Work Environment Sexual Harassment)
Motion to Enter Default C.R.C.P. 55(a)
MOTION TO ENTER DEFAULT C.R.C.P. 55(a)
Defendant’s Answer, Cross-Claim and Jury Demand
DEFENDANT’S ANSWER, CROSS-CLAIM AND JURY DEMAND cross claim for breach of contract and promissory estoppel
Wrongful Death Complaint
Wrongful Death complaint and loss of consortium
Complaint for Negligence Against Ski Area
The four elements that a plaintiff must prove to win a negligence suit are 1) Duty, 2) Breach, 3) Cause, and 4) Harm. Generally speaking, when someone acts in a careless way and causes an injury to another person, under the legal principle of “negligence” the careless person will be legally liable for any resulting harm. Ski Resort Immunity and Inherent Risk of Skiing protects the ski resort from most claims of negligence – which usually must be proved to win a personal injury lawsuit.
Motion for Extension of Time
motion for extension of time to file an asnwer
Motion to Deposit Funds with Registry of Court
Motion to deposit funds
Civil Action Complaint Seeking Interpleader Relief
CIVIL ACTION – COMPLAINT SEEKING INTERPLEADER RELIEF
Defendant’s Answer to Plaintiff’s Complaint and Jury Demand
DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT AND JURY DEMAND to negligence arguing comparative negligence
Unopposed Motion In Limine to Preclude Testimony Regarding Insurance Coverage
UNOPPOSED MOTION IN LIMINE TO PRECLUDE PLAINTIFFS’ TESTIMONY REGARDING INSURANCE COVERAGE
Plaintiff’s Supplemental Motion in Limine
PLAINTIFF’S SUPPLEMENTAL MOTION IN LIMINE excluded defendant bringing up how small their business is
Plaintiff’s Proposed Jury Instructions – Personal Injury
PLAINTIFF’S PROPOSED JURY INSTRUCTIONS