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Defendant's trial brief
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Leonard Martinez
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Notice of Objection (Governmental)
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Notice of Objection (Governmental) Subtotal: $75.00
Litigation
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PLAINTIFFS’ ADDITIONAL MOTION FOR ONE-DAY EXTENSION OF TIME
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Leonard Martinez
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.Â
$50.00
MOTION TO BIFURCATE TRIAL OF LIABILITY AND DAMAGES ISSUES
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Leonard Martinez
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.Â
$50.00
DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME FOR SUBMISSION OF REPLY IN SUPPORT OF MOTION FOR CLARIFICATION
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Leonard Martinez
Defendant’s unopposed motion for extension of time to provide a reply in support of motion for clarification.Â
$50.00
DEFENDANT’S THIRD MOTION IN LIMINE REGARDING RIGHTS VERSUS DUTIES
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Leonard Martinez
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.Â
$50.00
DEFENDANT’S SIXTH MOTION IN LIMINE REGARDING NAME
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Leonard Martinez
Defendant’s sixth motion in limine regarding the testimony of expert witness.Â
$50.00
DEFENDANT’S SECOND MOTION IN LIMINE REGARDING PEV AND RESERVE INFORMATION
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Leonard Martinez
Defendant’s second motion regarding PEV or reserve information.
$50.00
DEFENDANT’S MOTION FOR SUMMARY JUDGMENT
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Leonard Martinez
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
$50.00
DEFENDANT’S MOTION FOR PARTIAL SUMMARY JUDGMENT AS TO THE CONDUCT OF NAME
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Leonard Martinez
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
$50.00
DEFENDANT’S MOTIONS FOR DIRECTED VERDICT
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Leonard Martinez
Defendant’s motion for directed verdict under C.R.C.P 50.
$50.00
DEFENDANT’S MOTION FOR DETERMINATION OF LAW
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Leonard Martinez
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
$50.00
DEFENDANT’S MOTION FOR CLARIFICATION REGARDING THE COURT’S ORDER ON ITS FIRST MOTION IN LIMINE REGARDING HYPOTHETICAL SETTLEMENT SCENARIOS
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Leonard Martinez
Defendant’s motion for clarification regarding the court’s order on defendant’s first motion in limine regarding the hypothetical settlement scenarios.Â
$50.00
DEFENDANT’S FOURTH MOTION IN LIMINE REGARDING NAME
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Leonard Martinez
Defendant’s fourth motion in limine regarding conduct, advice, actions or inaction of plaintiff’s witness.Â
$50.00
DEFENDANT’S FIFTH MOTION IN LIMINE REGARDING NAME VALUATIONS
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Leonard Martinez
Defendant’s fifth motion in limine regarding valuations performed by a person that is an expert witness for plaintiff.Â
$50.00
DEFENDANT’S EMERGENCY MOTION FOR TELEPHONIC HEARING
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Leonard Martinez
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
$50.00