Plaintiff’s Motion for Leave to Amend Complaint & Add Punitive Damages
Plaintiff’s Motion for Leave to Amend Complaint & Add Punitive Damages
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 Strike Defendant’s Expert Disclosures of M.D.
PLAINTIFF’S MOTION TO STRIKE DEFENDANT’S FOURTH SUPPLEMENTAL C.R.C.P. 26(a)(2) EXPERT DISCLOSURES OF , M.D.
Plaintiff’s Motion to Strike Testimony
Plaintiff’s Motion to Strike Testimony
Plaintiff’s Notice of Errata Relative to her Election to Receive Immediate Payment
PLAINTIFF’S NOTICE OF ERRATA RELATIVE TO HER ELECTION TO RECEIVE IMMEDIATE PAYMENT OF THE PRESENT VALUE OF THE FUTURE DAMAGE AWARD IN A LUMP-SUM AMOUNT IN LIEU OF PERIODIC PAYMENTS
Plaintiff’s Post-Trial Motion to Exceed the $1,000,000.00 Cap
PLAINTIFF’S POST-TRIAL MOTION TO EXCEED THE $1,000,000.00 CAP CONTAINED IN C.R.S. § 13-64-302(1)(b)
Plaintiff’s Proposed Jury Instructions – Personal Injury
PLAINTIFF’S PROPOSED JURY INSTRUCTIONS
Plaintiff’s Proposed Jury Instructions on Insurance Collateral
PLAINTIFF’S PROPOSED JURY INSTRUCTION ON INSURANCE Collateral source
Plaintiff’s Response to Motion for New Trial – Medical Malpractice
PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION FOR NEW TRIAL
Plaintiff’s Response to Motion for Summary Judgment
PLAINTIFF’S RESPONSE TO MOTION FOR SUMMARY JUDGMENT AND MOTION TO ACCEPT PUNITIVE DAMAGES AND OUTRAGEOUS CONDUCT CLAIM
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
Plaintiff’s Memorandum Brief in Opposition to Defendant, M.D.’S C.R.M. 7 Petition for Review of Magistrate’s Order
PLAINTIFF’S MEMORANDUM BRIEF IN OPPOSITION TO DEFENDANT , M.D.’S C.R.M. 7 PETITION FOR REVIEW OF MAGISTRATE’S ORDER
Plaintiff’s Motion for Leave to Amend Complaint to add Additional Defendant
PLAINTIFF’S MOTION FOR LEAVE TO AMEND COMPLAINT TO ADD ADDITIONAL DEFENDANT
Plaintiff’s Motion for Leave to Amend Complaint to add Punitive Damages Against Defendants and Company
PLAINTIFF’S MOTION FOR LEAVE TO AMEND COMPLAINT TO ADD PUNITIVE DAMAGES AGAINST DEFENDANTS AND COMPANY
Plaintiff’s Motion in Limine to Exclude Evidence of Prior Felony
PLAINTIFF’S MOTION IN LIMINE TO EXCLUDE EVIDENCE OF PRIOR FELONY