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Defendant’s Answer, Cross-Claim and Jury Demand
DEFENDANT’S ANSWER, CROSS-CLAIM AND JURY DEMAND cross claim for breach of contract and promissory estoppel
DEFENDANT’S COMBINED REPLY IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT, MOTION FOR DETERMINATION OF LAW, AND MOTION FOR PARTIAL SUMMARY JUDGMENT AS TO THE CONDUCT
Defendant’s combined reply in support of motions for summary judgment, motion for determination of law, and motion for partial summary judgement as to the conduct of a person.Â
DEFENDANT’S EMERGENCY MOTION FOR TELEPHONIC HEARING
Defendant’s counsel certifies that he has attempted to contact plaintiff’s counsel several times and received no response prior to filing this motion. Defendant filed a motion in Limine regarding hypothetical settlement scenarios.Â
DEFENDANT’S FIFTH MOTION IN LIMINE REGARDING NAME VALUATIONS
Defendant’s fifth motion in limine regarding valuations performed by a person that is an expert witness for plaintiff.Â
DEFENDANT’S FIRST MOTION IN LIMINE REGARDING HYPOTHETICAL SETTLEMENT SCENARIOS
Defendant’s first motion in limine regarding the hypothetical settlement scenarios that states the pursuant to CRCP 121, counsel certifies conferral with counsel for plaintiff who objects to the relief requested.Â
DEFENDANT’S FOURTH MOTION IN LIMINE REGARDING NAME
Defendant’s fourth motion in limine regarding conduct, advice, actions or inaction of plaintiff’s witness.Â
DEFENDANT’S MEMORANDUM IN SUPPORT OF ITS MOTION TO DISMISS
PLAINTIFF sued DEFENDANT for breach of contract and misappropriation of trade secrets. PLAINTIFF does not, however, allege that DEFENDANT actually breached the contract nor does it have any evidence whatsoever that he has misappropriated trade secrets.
Defendant’s Motion for Attorney Fees and Costs
DEFENDANTS’ MOTION FOR ATTORNEY FEES AND COSTS
DEFENDANT’S MOTION FOR CLARIFICATION REGARDING THE COURT’S ORDER ON ITS FIRST MOTION IN LIMINE REGARDING HYPOTHETICAL SETTLEMENT SCENARIOS
Defendant’s motion for clarification regarding the court’s order on defendant’s first motion in limine regarding the hypothetical settlement scenarios.Â
DEFENDANT’S MOTION FOR DETERMINATION OF LAW
Defendant’s pursuant to C.R.C.P 56, makes the motion for determination of law: pursuant to C.R.C.P. 121, undersigned counsel certifies conferral with counsel for plaintiff who objects to the relief requested in this motion.Â
Defendant’s Motion for Leaving to Conduct Ex Parte Meetings with some of Plaintiff’s Treating Health Care Providers
DEFENDANT’S MOTION FOR LEAVE TO CONDUCT EX PARTE MEETINGS WITH SOME OF PLAINTIFF’S TREATING HEALTH CARE PROVIDERS
DEFENDANT’S MOTION FOR PARTIAL SUMMARY JUDGMENT AS TO THE CONDUCT OF NAME
Defendant’s motion for partial summary judgment, as to the conduct of plaintiff’s witness, follows the pursuant to C.R.C.P 121, counsel certifies conferral with counsel for plaintiff who objects to the relief requested in this motion. Â
DEFENDANT’S MOTION FOR SUMMARY JUDGMENT
Defendant’s pursuant to C.R.C.P. 56, makes the following motion for summary judgement: pursuant to C.R.C.P 121, undersigned counsel certifies conferral with counsel for plaintiff who objects to the relief requested in this motion.Â
DEFENDANT’S MOTION IN LIMINE RE: PLAINTIFF’S UPLEAD THEORY OF LIABILITY
DEFENDANT’S MOTION IN LIMINE RE: PLAINTIFF’S UPLEAD THEORY OF LIABILITY
Defendant’s Motion in Limine to Preclude Evidence
DEFENDANT’S MOTION IN LIMINE TO PRECLUDE EVIDENCE OR ARGUMENT REGARDING TRAFFIC CITATIONS, DRIVING RECORDS
AND PRIOR UNRELATED TRAFFIC OFFENSES/CHARGES