Civil Litigation
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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 Compel Production of Documents and for Expedited Hearing
PLAINTIFF’S MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND FOR EXPEDITED HEARING in an employment Title vII case
Plaintiff’s Motion for Evidentiary Hearing on Back Pay
PLAINTIFF’S MOTION FOR EVIDENTIARY HEARING ON BACK PAY after receiving a judgment on title VII case
Plaintiff’s Motion for Attorney Fees
After receiving a judgment in employment case Plaintiff is requesting attorney fees as prevailing party
Defendat’s Combined Motions in Limine
DEFENDANT’S COMBINED MOTIONS IN LIMINE
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)
Motion to Vacate Bench Warrant
MOTION TO VACATE BENCH WARRANT for a civil show cause order
Motion to Preclude Expert From Offering Testimony Outside the Scope of Previously Disclosed Opinions
PLAINTIFF’S SUPPLEMENT TO MOTION IN LIMINE TO PRECLUDE ANY EXPERT FROM OFFERING OPINIONS OR TESTIMONY OUTSIDE THE SCOPE OF THEIR PREVIOUSLY DISCLOSED OPINIONS
Plaintiff’s Motion to Strike Certain Opinions of Defendant – Malpractice
PLAINTIFF’S MOTION TO STRIKE CERTAIN OPINIONS OF DEFENDANT,
AND NAME
Motion to Strike Defendant’s Affirmative Defense & Preclusion of Inadmissable Evidence
PLAINTIFF’S MOTION TO STRIKE DEFENDANT’S AFFIRMATIVE DEFENSE OF NONPARTY AT FAULT AND TO PRECLUDE INADMISSABLE EVIDENCE CONCERNING ALLEGED NEGLIGENCE OR FAULT OF UNIVERSITY OF COLORADO PROVIDERS
Unopposed Motion to Take Deposition Outside of Discovery Deadline
PLAINTIFF’S UNOPPOSED MOTION TO TAKE DEPOSITION OUTSIDE OF THE DISCOVERY DEADLINE
Plaintiff’s Motion for Leave to Submit Under Seal
PLAINTIFF’S MOTION FOR LEAVE TO SUBMIT UNDER SEAL AND FOR IN CAMERA REVIEWOFCONFIDENTIAL EXHIBIT 9 TO PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION FOR LEAVE TO CONDUCT EX PARTE MEETINGS WITH SOME OF PLAINTIFF’S TREATING HEALTH CARE PROVIDERS, HEARING REQUESTED
Motion for Reconsideration of Ruling & Petition for Review of Magistrate’s Order
PLAINTIFF’S MOTION FOR RECONSIDERATION OF DISTRICT COURT’S RULING AND ORDER ON PETITION FOR REVIEW OF MAGISTRATE’S ORDER
Defendants Motion for Summary Judgment – Employment Law
Brief and motion for summary judgment Title VII Discrimination, (2) Wrongful Discharge in Violation of Public Policy as set forth in the Colorado Anti-Discrimination Act, C.R.S. 24-34-402, and (3) Violation of the Colorado Wage Claim Act, C.R.S. 8-4-101.
Defendant’s Motion to Waive Mediation Requirement
DEFENDANT’S MOTION TO WAIVE MEDIATION REQUIREMENT