Civil Litigation
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Plaintiffs’ Opposition to Motion to Dismiss Defendants
Plaintiff’s opposition to defendant’s motion to dismiss the complaint.
Defendants’ Motion to Coordinate Depositions
Defendant’s motion to move to coordinate the depositions between the related cases currently pending in two district courts.Â
Plaintiffs’ Opposition to Defendants’ Motion to Coordinate Depositions
Defendant’s motion to have Plaintiffs action to coordinate the depositions of defendant’s employees with separate federal court cases all to the prejudice of plaintiffs herein.Â
Unopposed Motion for Leave to File First Amended Complaint and Jury Demand
Plaintiff’s unopposed motion for leave to file first amended complaint and jury demand.
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Defendants’ Motion for a Protective Order to Sequence Discovery on Liability
A motion for protective order refers to a party’s request that the court protect it from potentially abusive action by the other party. Such a request is often made in relation to discovery, as when one party seeks discovery of the other party’s trade secrets. A protective order from discovery protects the person who would otherwise have to provide discovery (e.g. answer interrogatories, answer deposition questions on a subject, provide documents responsive to a request for production of documents, to allow someone to inspect premises, or to participate in a forensic medical.
Motion for Order Authorizing Production of Records Pursuant to Colo. R. CIV. P. 45(c)(2)(B) and Request for Expedited Ruling
MOTION FOR ORDER AUTHORIZING PRODUCTION OF RECORDS PURSUANT TO COLO. R. CIV. P. 45(c)(2)(B) AND REQUEST FOR EXPEDITED RULING
Plaintiffs’ Motion to Exclude Defendants’ Designated Experts Pursuant to C.R.E. 702
Defendant’s motion for an Order excluding at the trial of this matter the testimony of four purported experts proffered by Defendants
Defendants’ Combined Motions in Limine
Defendants motion to exclude from trial testimony and evidence of (1) expiration of the statute of limitations against; (2) Defendants’ budget, profit, and bonus policies; (3) irrelevant previous crimes; (4) Defendants’ firearm policy; (5) subsequent remedial measures; (6) Defendants’ alleged failure to produce evidence; (7) Plaintiffs’ injuries; (8) insurance coverage; and (9) placing the jury into the Plaintiffs’ position.
Plaintiffs’ Motion in Limine to Preclude Defendants From Referencing the Biographical Backgrounds of Counsel
PLAINTIFFS’ MOTION IN LIMINE TO PRECLUDE DEFENDANTS FROM REFERENCING THE BIOGRAPHICAL BACKGROUNDS OF COUNSEL
Plaintiffs’ Motion in Limine to Preclude Defendant from Referencing Other Specific Mass Casualty Events
Plaintiff’s motion for Defendants, their counsel and their witnesses from making or espousing statements, opinions or arguments at trial concerning, pertaining to or relating to specific other mass casualty events
Plaintiffs’ Motion in Limine to Preclude Defendants from Referencing Movie Theater Industry Security Standard, Protocols or Practices
PLAINTIFFS’ MOTION IN LIMINE TO PRECLUDE DEFENDANTS FROM REFERENCING MOVIE THEATER INDUSTRY SECURITY STANDARDS, PROTOCOLS OR PRACTICES
Plaintiffs’ Motion in Limine to Preclude Defendants from Referencing Legally Incorrect Standard of Foreseeability Under Colorado’s Premises Liability Statue
PLAINTIFFS’ MOTION IN LIMINE TO PRECLUDE DEFENDANTS FROM REFERENCING LEGALLY INCORRECT STANDARD OF FORESEEABILITY UNDER COLORADO’S PREMISES LIABILITY STATUTE