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.
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
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.
Defendat’s Combined Motions in Limine
DEFENDANT’S COMBINED MOTIONS IN LIMINE
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
Defendant’s Response to Plaintiff’s Post-Trial Motion to Exceed the $1,000,000.00 Cap
DEFENDANT’S RESPONSE TO 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 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)
Defendant’s Post-Trial Motion to Reduce Jury Verdict in Accordance with HCAA’S CAPS
DEFENDANT’S POST-TRIAL MOTION TO REDUCE THE JURY VERDICT IN ACCORDANCE WITH THE HCAA’S CAPS
Defendant’s Response to Plaintiff’s Motion on Admissibilty of Insurance for Purposes of Establishing Bias
DEFENDANT’S RESPONSE TO PLAINTIFF’S TRIAL BRIEF (MOTION IN LIMINE) ON ADMISSIBILITY OF INSURANCE FOR PURPOSES OF ESTABLISHING BIAS
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 Proposed Jury Instructions on Insurance Collateral
PLAINTIFF’S PROPOSED JURY INSTRUCTION ON INSURANCE Collateral source
Motion in Limine to Exclude Damages Evidence from Trial
DEFENDANT’S MOTION IN LIMINE TO EXCLUDE DAMAGES EVIDENCE FROM TRIAL
Defendant’s Motion for Summary Judgment Pursuant to C.R.C.P. Rule 56(b)
DEFENDANT’S MOTION FOR SUMMARY JUDGMENT PURSUANT TO C.R.C.P. RULE 56(b) Plaintiff has Suffered no Damages
Motion in Limine to Exclude Evidence
By failing to object to the timeline stated in the agreed to presumptive Case Management Order, Plaintiff is barred from introducing any evidence or calling any witnesses not disclosed prior to the October 19, 2008 discovery cut-off date
Defendant’s Designation for Non Parties at Fault
DEFENDANT’S DESIGNATION OF NON-PARTIES AT FAULT