Defendants’ Notice of Removal – Personal Injury
Defendant’s notice of removal to remove the instant case to the United States District Court for the District of Colorado. A notice of removal is signed by the defendants and filed in federal court to begin the process of transferring the civil action from state court to federal court. Promptly after the filing of such notice of removal of a civil action the defendant or defendants shall give written notice thereof to all adverse parties and shall file a copy of the notice with the clerk of such State court, which shall effect the removal and the State court shall proceed no further.
Defendants’ Trial Brief – Personal Injury
A trial brief sets forth the facts, evidence, and legal arguments the party intends to present at trial. A trial brief includes issue, which identify the issue raised by the facts of the client’s case. Rule , which identify the law(s) that controls the issue(s). Analysis, which explains how the rule of law apply to the issue(s). Conclusion, which is a summary of the legal analysis.
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.
Defendants’ Joint Unopposed Motion for an Enlargement of Time to Designate Non-parties at Fault Pursuant to C.R.S. § 13-21-111.5 and Request for Ruling Forthwith
DEFENDANTS’ JOINT UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO DESIGNATE NONPARTIES AT FAULT PURSUANT TO C.R.S. § 13-21-111.5 AND REQUEST FOR RULING FORTHWITH
Defendants’ Motion for an Award of Costs
DEFENDANTS’ MOTION FOR AN AWARD OF COSTS
Defendants’ Response to New York Attorney’s Rule 221 Motion
Defendant’s response to New York attorney’s rule 221 motion requesting permission to appear as counsel for Plaintiffs in this case.Â
Defendat’s Combined Motions in Limine
DEFENDANT’S COMBINED MOTIONS IN LIMINE
Federal Civil Complaint under 42 USC 1983 (Excessive Force)
Civil Complaint pursuant to 42 USC 1983 for police use of excessive force. US District Court for the Eastern District of Michigan.
First Amended Complaint and Jury Demand
Plaintiffs pursuant to C.R.C.P. 25(a), respectfully submit the following First Amended Complaint and Jury Trial Demand.
Hospital writeoff gifts, Motion in limine
Motion in limine regarding Hospital write offs are gifts that are still recoverable as medical specials
Jury instructions
Full set of jury instructions for premise liability dangerous roof
LIMITATION OF LIABILITY COMPLAINT (ADMIRALTY)
Little-known wrinkle in Federal Admiralty & Maritime Law allows potential defendant to limit his potential liability to the value of the subject vessel. **Extremely useful to insurance/subrogation lawyers.