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Biomechanic opinions re injuries, MIL to exclude
Motion in limine to preclude biomechanicist’s opinion re injuries
Punitive Damages, Motion for Leave to Amend to Add
Motion to Permit Amending Complaint to Allege Punitive Damages
Product Liability Lawsuit – Federal Court Civil Complaint and Jury Demand
Federal Court Civil Complaint, including claims for Strict Liability, Product Liability-Failure to Warn, Negligence, Breach of Warranty- Express and Implied, Fraud, Fraudulent Concealment, and Negligent Representation.
Product liability is the area of law in which manufacturers, distributors, suppliers, retailers, and others who make products available to the public are held responsible for the injuries those products cause.
Product Defects: Responsible Parties
For product liability to arise, at some point the product must have been sold in the marketplace. Historically, a contractual relationship, known as “privity of contract,” had to exist between the person injured by a product and the supplier of the product in order for the injured person to recover. In most states today, however, that requirement no longer exists, and the injured person does not have to be the purchaser of the product in order to recover. Any person who foreseeably could have been injured by a defective product can recover for his or her injuries, as long as the product was sold to someone.
Liability for a product defect could rest with any party in the product’s chain of distribution, such as:
-The product manufacturer;
-A manufacturer of component parts;
-A party that assembles or installs the product;
-The wholesaler; and
-The retail store that sold the product to the consumer.
Defendant’s Motion in Limine to Preclude Evidence Pertaining to Impairment Ratings
DEFENDANT’S MOTION IN LIMINE TO PRECLUDE EVIDENCE PERTAINING TO IMPAIRMENT RATINGS
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
Federal Civil Complaint under 42 USC 1983 (Excessive Force)
Civil Complaint pursuant to 42 USC 1983 for police use of excessive force. US District Court for the Eastern District of Michigan.
Plaintiff’s Response and Objections to Notice to Take the Videotaped Deposition of and Subpoena Duces Tecum
PLAINTIFF’S RESPONSE AND OBJECTIONS TO NOTICE TO TAKE THE VIDEOTAPED DEPOSITION aND SUBPOENA DUCES TECUM
Defendants Company Trial Brief on Improper Argument of Defendant’s ongoing Employment
DEFENDANT COMPANY TRIAL BRIEF ON IMPROPER ARGUMENT OF DEFENDANT’S ONGOING EMPLOYMENT in auto accident case
Plaintiff’s Memorandum Brief in Opposition to Defendant, M.D.’S C.R.M. 7 Petition for Review of Magistrate’s Order
PLAINTIFF’S MEMORANDUM BRIEF IN OPPOSITION TO DEFENDANT , M.D.’S C.R.M. 7 PETITION FOR REVIEW OF MAGISTRATE’S ORDER
Defendant Company Trial Brief Re: Negligent Entrustment Claim
DEFENDANT COMPANY TRIAL BRIEF RE: NEGLIGENT ENTRUSTMENT CLAIM in auto accident
Defendant C.R.M. 7 Petition for Review of Magistrate’s Order
DEFENDANT C.R.M. 7 PETITION FOR REVIEW OF MAGISTRATE’S ORDER
Defendant’s Initial Rule 26 Disclosures – Personal Injury
A party must make its initial disclosures based on the information then reasonably available to it. In addition to the disclosures required by Rule 26(a)(1), a party must disclose to the other parties the identity of any witness it may use at trial to present evidence under Federal Rule of Evidence 702, 703, or 705. Appendix A to these disclosures identifies those individuals who may have discoverable information relevant to disputed facts alleged with particularity in the pleadings.
Motion to Preclude Client from Introducing Evidence or Testimony – Plaintiff was not Informed of Her Right to Undergo Testing
PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION IN LIMINE TO PRECLUDE PLAINTIFF FROM ARGUING, OR INTRODUCING EVIDENCE OR TESTIMONY, THAT PLAINTIFF WAS NOT INFORMED OF HER RIGHT ON AUGUST 1, 2012, TO UNDERGO TESTING TO DEFINITIVELY RULE OUT THE POSSIBILITY OF INFECTION
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