Personal Injury
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Reply in Support of Motion for Pro Hac Vice Admission
Plaintiff’s reply in support of defendant’s motion for pro hac vice admission.Â
Response to Plaintiffs’ Motion to Exclude Defendants’ Experts
 Plaintiff’s motion to limit the testimony of four of the defendants’ experts.Â
Amended answer to PI lawsuit
Amended answer for a auto accident case, whereas the manufacturer was sued for defective vehicle. Sample answers including not doing business in state of Colorado, other affirmative defenses.
ANSWER-Personal Injury, Property Damage, Wrongful Death
ANSWER-Personal Injury, Property Damage, Wrongful Death
Plaintiff’s Response and Objections to Notice to Take the Videotaped Deposition of and Subpoena Duces Tecum
PLAINTIFF’S RESPONSE AND OBJECTIONS TO NOTICE TO TAKE THE VIDEOTAPED DEPOSITION aND SUBPOENA DUCES TECUM
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 Response to Motion for New Trial – Medical Malpractice
PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION FOR NEW TRIAL
Defendant’s Response to Plaintiff’s Motion to Exclude Standard of Care Opinions
DEFENDANT’S RESPONSE TO PLAINTIFF’S MOTION TO EXCLUDE STANDARD OF CARE OPINIONS BY —, PURSUANT TO C.R.E. 702
Response to Defendant’s Motion to Preclude Argument Regarding Defendant’s Responsibility
PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION IN LIMINE TO PRECLUDE ARGUMENT REGARDING DEFENDANTS’ RESPONSIBILITY
Response to Motion to Preclude Evidence Pertaining to Impairment Ratings
PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION IN LIMINE TO PRECLUDE EVIDENCE PERTAINING TO IMPAIRMENT RATINGS
Plaintiff’s Response to Defendant Company Motion for More Definite Statement
PLAINTIFF’S RESPONSE TO DEFENDANT COMPANY MOTION FOR MORE DEFINITE STATEMENT
Response to Motion for Separate Trials
Response to motion for separate trials
Response to Motion in Limine to Exclude Evidence of Traffic Citation and Conviction
DEFENDANTS’ RESPONSE TO PLAINTIFF’S MOTION IN LIMINE TO EXCLUDE EVIDENCE OF TRAFFIC CITATION AND TRAFFIC CONVICTION
Response to Motion in Limine to Exclude Evidence of Prior Felony Conviction
DEFENDANTS’ RESPONSE TO PLAINTIFF’S MOTION IN LIMINE TO EXCLUDE EVIDENCE OF PRIOR FELONY CONVICTION
Response to Motion in Limine RE: Undisclosed Expert Opinions
DEFENDANTS’ RESPONSE TO PLAINTIFF’S MOTION IN LIMINE RE: UNDISCLOSED EXPERT OPINIONS