Litigation
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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).
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 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
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)
Motion to Preclude Expert From Offering Testimony Outside the Scope of Previously Disclosed Opinions
PLAINTIFF’S SUPPLEMENT TO MOTION IN LIMINE TO PRECLUDE ANY EXPERT FROM OFFERING OPINIONS OR TESTIMONY OUTSIDE THE SCOPE OF THEIR PREVIOUSLY DISCLOSED OPINIONS
Plaintiff’s Motion to Strike Certain Opinions of Defendant – Malpractice
PLAINTIFF’S MOTION TO STRIKE CERTAIN OPINIONS OF DEFENDANT,
AND NAME
Plaintiff’s Motion for Leave to Submit Under Seal
PLAINTIFF’S MOTION FOR LEAVE TO SUBMIT UNDER SEAL AND FOR IN CAMERA REVIEWOFCONFIDENTIAL EXHIBIT 9 TO PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION FOR LEAVE TO CONDUCT EX PARTE MEETINGS WITH SOME OF PLAINTIFF’S TREATING HEALTH CARE PROVIDERS, HEARING REQUESTED
Plaintiffs Unopposed Motion to Amend Complaint
PLAINTIFFS’ UNOPPOSED MOTION TO AMEND COMPLAINT
Plaintiffs’ Unopposed Motion to Amend Complaint
PLAINTIFFS’ UNOPPOSED MOTION TO AMEND COMPLAINT
Plaintiffs’ Motion to Terminate Application of Rule 16.1
PLAINTIFFS’ MOTION TO TERMINATE APPLICATION OF RULE 16.1
Plaintiff’s Motion and Brief for Summary Judgment on Defendants and Trust’s Counterclaims
PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT ON DEFENDANTS AND TRUST’S COUNTERCLAIMS WITH BRIEF
Motion to Dismiss Defendant – Civil Litigation
The Complaint is vague, insubstantial and attenuated as to the facts regarding Defendant
Motion for Sanctions for Willful Refusal to Produce Documents
Motion for Sanctions for Plaintiff’s Willful Refusal to Comply with the Court’s Order to Produce Documents
DEFENDANT’S motion to enter judgment in Defendant
DEFENDANT’S NAME moves the Court to enter judgment in Defendant