Civil Litigation
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PLAINTIFFS’ COMBINED RESPONSE TO DEFENDANT’S RULE 56 MOTIONS
PLAINTIFFS’ COMBINED RESPONSE TO DEFENDANT’S RULE 56 MOTIONS
PLAINTIFFS’ ADDITIONAL MOTION FOR ONE-DAY EXTENSION OF TIME
Plaintiff’s additional motion for one-day extension of time to file responses to defendant’s motion for summary judgement, motion for determination of law and motion for partial summary judgment as to the conduct of expert.
MOTION TO BIFURCATE TRIAL OF LIABILITY AND DAMAGES ISSUES
Defendant’s motion to move pursuant to C.R.C.P 42 to bifurcate the trial of liability issues from the trial of damages issues.
JOINT REQUEST FOR RULING ON OUTSTANDING ISSUE
Plaintiff and defendant’s joint request for ruling an outstanding issue.
DEFENDANT’S UNOPPOSED REQUEST FOR CLARIFICATION AND RULING
Defendant’s unopposed request for clarification and ruling states that the undersigned counsel conferred with counsel for plaintiff who does not object to the relief requested in the motion.
DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME FOR SUBMISSION OF REPLY IN SUPPORT OF MOTION FOR CLARIFICATION
Defendant’s unopposed motion for extension of time to provide a reply in support of motion for clarification.
Defendant’s trial brief
Defendant’s trial brief addresses the direction to the parties on the which will be provided to the jury including whether Soriano is now the law of the case and whether the defendant can challenge the reasonableness of the arbitration award.
DEFENDANT’S THIRD MOTION IN LIMINE REGARDING RIGHTS VERSUS DUTIES
Defendant’s third motion in limine regarding rights versus duties states that pursuant to CRCP 121, counsel certifies conferral with counsel for plaintiff who object to the relief requested.
DEFENDANT’S SIXTH MOTION IN LIMINE REGARDING NAME
Defendant’s sixth motion in limine regarding the testimony of expert witness.
DEFENDANT’S SECOND MOTION IN LIMINE REGARDING PEV AND RESERVE INFORMATION
Defendant’s second motion regarding PEV or reserve information.
DEFENDANT’S RESPONSE TO PLAINTIFFS’ MOTION TO AMEND COMPLAINT TO INCLUDE A PRAYER FOR EXEMPLARY DAMAGES
Defendant’s response to plaintiff’s motion to amend complaint to include a prayer for exemplary damages.
DEFENDANT’S RESPONSE TO PLAINTIFFS’ MOTION IN LIMINE RE: DEFENDANT’S NAME INSURANCE EXCHANGE’S “OPPORTUNITY TO SETTLE”
Defendant’s response and objections to plaintiff’s motion regarding defendant’s “opportunity to settle”.
DEFENDANT’S REQUEST FOR RECONSIDERATION OF COURT’S ORDER RE: DEPOSITION
Defendant’s requests the court to reconsider objections which were upheld by Division 3 in their review of the deposition of expert.
DEFENDANT’S REPLY TO PLAINTIFFS’ RESPONSE TO FIRST MOTION IN LIMINE REGARDING HYPOTHETICAL SETTLEMENT SCENARIOS
Defendant’s reply to plaintiff’s response to the first motion regarding hypothetical settlement scenarios.