PLAINTIFFS’ MOTION FOR LEAVE TO FILE COMBINED RESPONSE TO DEFENDANT’S RULE 56 MOTIONS OUT OF TIME
Plaintiff’s motion to request that the court permit them to file their combined response to defendant’s rule 56 motions out of time.
PLAINTIFFS’ MOTION FOR LEAVE TO FILE RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION TO BIFURCATE TRIAL OF LIABILITY AND DAMAGES ISSUES OUT OF TIME
Plaintiff’s motion for leave to file response in opposition to defendant’s motion to bifurcate trial of liability and damages issues out of time.
PLAINTIFFS’ MOTION TO AMEND COMPLAINT TO INCLUDE A PRAYER FOR EXEMPLARY DAMAGES
Plaintiff’s motion that requests that the court enter an order permitting them to amend their complaint to include a prayer for exemplary damages.
PLAINTIFFS’ REPLY IN SUPPORT OF MOTION TO AMEND COMPLAINT TO INCLUDE A PRAYER FOR EXEMPLARY DAMAGES
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PLAINTIFFS’ REPLY IN SUPPORT OF MOTION TO AMEND COMPLAINT TO INCLUDE A PRAYER FOR EXEMPLARY DAMAGES |
PLAINTIFFS’ RESPONSE IN OPPOSITION TO DEFENDANT’S FOURTH MOTION IN LIMINE REGARDING
Plaintiff’s response in opposition to defendant’s fourth motion in limine regarding expert.
PLAINTIFFS’ RESPONSE IN OPPOSITION TO DEFENDANT’S THIRD MOTION IN LIMINE REGARDING RIGHTS VERSUS DUTIES
Plaintiff’s response in opposition to defendant’s third motion in limine regarding rights versus duties.
PLAINTIFFS’ RESPONSE TO DEFENDANT’S FIFTH MOTION IN LIMINE REGARDING MILLER VALUATIONS
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PLAINTIFFS’ RESPONSE TO DEFENDANT’S FIFTH MOTION IN LIMINE REGARDING MILLER VALUATIONS. |
PLAINTIFFS’ RESPONSE TO DEFENDANT’S MOTION FOR CLARIFICATION OF ORDER RE: HYPOTHETICAL SETTLEMENT SCENARIOS
PLAINTIFFS’ RESPONSE TO DEFENDANT’S MOTION FOR CLARIFICATION OF ORDER RE: HYPOTHETICAL SETTLEMENT SCENARIOS
PLAINTIFFS’ FINAL LIST OF REMAINING OBJECTIONS FROM PRESERVATION DEPOSITION OF — THAT REQUIRE RULINGS
Plaintiff states their final list of remaining objections from preservation deposition of expert that require rulings.
PLAINTIFFS’ MOTION IN LIMINE RE: DEFENDANT’S “OPPORTUNITY TO SETTLE”
Plaintiff’s motion in limine Re: Defendant’s “opportunity to settle”
PLAINTIFFS’ REPLY IN SUPPORT OF MOTION IN LIMINE RE: DEFENDANT’S “OPPORTUNITY TO SETTLE”
Plaintiff’s reply in support of motion in limine RE: defendant’s “opportunity to settle”.
Response Breif In Response to Motion for Summary Adjucation
Response brief for a motion to summary judgment. Case involved an life insurance dispute and the right to benefits. One party filed a motion for summary judgement, we filed a response and the motion was denied and we won the trial.
Response Brief to Motion for Summary Judgment
Insurance interpleader case where there was a dispute as to who gets a life insurance policy. I represented the name beneficiary and the other party was the descendants two daughters. The daughters claimed they were entitled to insurance proceeds because he was required to pay child support. This my response to their motion for summary judgment.
Settlement Demand for an Auto Accident Case
A simple settlement letter to insurance company for auto accident. I also attached the settlement calculation breakdown sheet. A demand letter is one of the most important steps in a car insurance claim after an accident. In the demand letter, the injured claimant sets out the facts and circumstances of the accident and resulting medical treatment, and sets the stage for injury settlement negotiations to begin in earnest.
Subject Matter Jurisdiction Brief
Interpleader case where determination was to be made as to who was entitled to life insurance proceeds. Once insurance deposited funds to registry of court they were allowed to withdraw from case and there was no longer an issue of diversity for jurisdiction so court required brief as to why jurisdiction and venue was proper in federal court. Used in Colorado US Federal District court but may be used in all federal courts