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Response to Defendant’s Motion to Prohibit Plaintiff from Asking Any Medical Expert Whether the Conduct of Physicians, was “Foreseeable”
PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION IN LIMINE TO PROHIBIT PLAINTIFF FROM ASKING ANY MEDICAL EXPERT WHETHER THE CONDUCT OF , OR OTHER UCH PHYSICIANS, WAS “FORESEEABLE
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
Plaintiff’s Motion to Exclude Standard of Care Opinions by Name, M.D. Pusuant to C.R.E. 702
PLAINTIFF’S MOTION TO EXCLUDE STANDARD OF CARE OPINIONS BY NAME, M.D. PURSUANT TO C.R.E. 702
Motion to Confess Judgment on Promissory Note, Dismiss all Related Claims, and Request for Forthwith Ruling
MOTION TO CONFESS JUDGMENT ON PROMISSORY NOTE AND DISMISS ALL RELATED CLAIMS AND REQUEST FOR FORTHWITH RULING 2. Plaintiffs therefore respectfully request that the Court dismiss with prejudice all claims related to the Note, including Plaintiffs’ claim for Negligent Misrepresentation against Defendant– Water Shares (Plaintiffs’ Third Amended Complaint, Fifth Claim for Relief) and the Defendants’ Counterclaim for Breach of Contract under the terms of the Note (Defendants’ Answer, Jury Demand, and Counterclaim, First and Second Claims for Relief in the Counterclaim).
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 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 Response to Defendant’s Motion for Summary Judgment and Brief in Support Thereof
PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT AND BRIEF IN SUPPORT THEREOF on SEX-BASED HOSTILE WORKING ENVIRONMENT
Plaintiff’s Motion to Restrict Access
PLAINTIFF’S MOTION TO RESTRICT ACCESS to Plaintiff’s attorney medical records.
Defendat’s Combined Motions in Limine
DEFENDANT’S COMBINED MOTIONS IN LIMINE
Defendant’s Response in Opposition to Plaintiff’s Motion to Strike Defendant’s affirmative Defense of Nonparty at fault
DEFENDANT’S RESPONSE IN OPPOSITION TO PLAINTIFF’S MOTION TO STRIKE DEFENDANT’S AFFIRMATIVE DEFENSE OF NONPARTY AT FAULT
First Supplamental Response to Plaintiff’s Motion to Strike Defendant’s Affirmative Defense
DEFENDANT’S FIRST SUPPLEMENTAL RESPONSE TO PLAINTIFF’S SUPPLEMENT TO MOTION TO STRIKE DEFENDANT’S AFFIRMATIVE DEFENSE OF NONPARTY AT FAULT AND TO PRECLUDE INADMISSIBLE EVIDENCE CONCERNING ALLEGED NEGLIGENCE OR FAULT
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)
Plaintiff’s Response to Defendant’s C.R.M. 7 Petition for Review of Magistrate’s Order
PLAINTIFF’S RESPONSE TO DEFENDANT C.R.M. 7 PETITION FOR REVIEW OF MAGISTRATE’S ORDER RE: (1) PLAINTIFF’S MOTION TO STRIKE DEFENDANT’S FOURTH SUPPLEMENTAL C.R.C.P. 26(a)(2) EXPERT DISCLOSURE OF —; AND (2) PLAINTIFF’S MOTION TO STRIKE DEFENDANT’S EIGHTH SUPPLEMENTAL DISCLOSURE AND PRECLUDE OPINIONS OF
Defendant C.R.M. 7 Petition for Review of Magistrate’s Orders
DEFENDANT C.R.M. 7 PETITION FOR REVIEW OF MAGISTRATE’S ORDERS RE: (1) PLAINTIFF’S MOTION TO STRIKE DEFENDANT’S FOURTH SUPPLEMENTAL C.R.C.P. 26(a)(2) EXPERT DISCLOSURE OF ROGER NICHOLS, M.D; AND (2) PLAINTIFF’S MOTION TO STRIKE DEFENDANT’S EIGHTH SUPPLEMENTAL DISCLOSURE AND PRECLUDE OPINIONS OF —.