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Plaintiff Submit Jury Instruction with Cite – Personal Injury
Plaintiff submit jury instruction with cite
Plaintiff’s Amended Certificate of Conferral re His Motion for New Trial Pursuant to CRCP 59D, Hearing Requested
Plaintiff’s Amended Certificate of Conferral re His Motion for New Trial Pursuant to CRCP 59D, Hearing Requested
Plaintiff’s Brief on Comparative Negligence – Personal Injury
Comparative negligence is a partial legal defense that reduces the amount of damages that a plaintiff can recover in a negligence-based claim, based upon the degree to which the plaintiff’s own negligence contributed to cause the injury.
Comparative negligence states that when an accident occurs, the fault and or negligence of each party involved is based upon their respective contributions to the accident. This allows insurers to assign blame and pay claims accordingly.
Plaintiff’s C.R.C.P. 37(a)(2) Motion to Compel, and C.R.C.P. 37(a)(4) Motion for Expense
Plaintiff’s C.R.C.P. 37(a)(2) Motion to Compel, and C.R.C.P. 37(a)(4) Motion for Expense
Plaintiff’s Combined Motions in Limine
PLAINTIFF’S MOTIONS IN LIMINE
Plaintiff’s Election to Get Immediate Payment for Future Damages
PLAINTIFF’S ELECTION TO RECEIVE IMMEDIATE PAYMENT OF THE PRESENT VALUE OF THE FUTURE DAMAGE AWARD IN A LUMP-SUM AMOUNT IN LIEU OF PERIODIC PAYMENTS
Plaintiff’s Memorandum of Law on Economic Damages
PLAINTIFF’S MEMORANDUM OF LAW ON ECONOMIC DAMAGES
Plaintiff’s Motion for Leave to Amend Complaint & Add Punitive Damages
Plaintiff’s Motion for Leave to Amend Complaint & Add Punitive Damages
Plaintiff’s Motion for Leave to Assert Claim of Punitive Damages
Plaintiff’s Motion for Leave to Assert Claim of Punitive Damages
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
Plaintiff’s Motion for New Trial Pursuant to CRCP 59d
Plaintiff’s Motion for New Trial Pursuant to CRCP 59d
Plaintiff’s Motion for New Trial Pursuant to CRCP 59d – Hearing Requested
Plaintiff’s Motion for New Trial Pursuant to CRCP 59d – Hearing Requested
Plaintiff’s Motion for Order Allowing Inspection of Front Range Orthopaedics Records or Alternatively, For In Camera Review
Plaintiff’s Motion for Order Allowing Inspection of Front Range Orthopaedics Records or Alternatively, For In Camera Review
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.