Civil Litigation
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PATTERN INTERROGATORIES UNDER C.R.C.P. 369(g) – BUSINESS
used to gather information after judgment to collect
PLAINTIFF’S PROPOSED JURY INSTRUCTIONS (ANNOTATED)
PLAINTIFF’S PROPOSED JURY INSTRUCTIONS (ANNOTATED)
Answer and counterclaim to County Court
Client was sued for a past Chiropractic bill, however she believed she had the bill settled a year before. We answered and countered sued for violation of fair debt collection act.
Non Disclosure Agrrement
Used when an individual wants to share an idea but wants to protect the idea and does not want the individual to disclose or share with others.
DEFENDANT’S PROPOSED JURY INSTRUCTIONS
DEFENDANT’S PROPOSED JURY INSTRUCTIONS
Plaintiff’s First Amended Draft Jury Instructions and Verdict Forms
PLAIINTIFF’S FIRST AMENDED DRAFT JURY INSTRUCTIONS AND VERDICT FORMS Negligence, COMPARATIVE NEGLIGENCE OF PLAINTIFF — SINGLE DEFENDANT — NO DESIGNATED NONPARTY INVOLVED, NEGLIGENT MISREPRESENTATION CAUSING FINANCIAL LOSS IN A BUSINESS TRANSACTION — ELEMENTS OF LIABILITY, BREACH OF EXPRESS WARRANTY UNDER U.C.C. — ELEMENTS OF LIABILITY
Joint Stipulated Case Management
Joint Stipulated Motion for Entry of Modified Case Management Order and adopt the deadlines and discovery limitations contained herein
Defendant’s Initial Rule 26 Disclosures – Personal Injury
A party must make its initial disclosures based on the information then reasonably available to it. In addition to the disclosures required by Rule 26(a)(1), a party must disclose to the other parties the identity of any witness it may use at trial to present evidence under Federal Rule of Evidence 702, 703, or 705. Appendix A to these disclosures identifies those individuals who may have discoverable information relevant to disputed facts alleged with particularity in the pleadings.
Plaintiff’s Proposed Jury Instructions on Insurance Collateral
PLAINTIFF’S PROPOSED JURY INSTRUCTION ON INSURANCE Collateral source
Affidavit of Attorney’s Fees & Costs on Motion to Compel
AFFIDAVIT OF ATTORNEY’S FEES AND COSTS on motion to compel
Proposed Stipulated Jury Instructions – Personal Injury
PARTIES’ PROPOSED STIPULATED JURY INSTRUCTIONS
Plaintiff’s Election to Get Immediate Payment for Future Damages
PLAINTIFF’S ELECTION TO RECEIVE IMMEDIATE PAYMENT OF THE PRESENT VALUE OF THE FUTURE DAMAGE AWARD IN A LUMP-SUM AMOUNT IN LIEU OF PERIODIC PAYMENTS