Plaintiffs’ Response to Motion to Dismiss by the Retail Property Trust and Simon Entities
Plaintiff’s Motion to Dismiss Plaintiffs’ Second Amended Complaint by the Retail Property Trust and Simon entities.Â
Plaintiffs’ Notice of Partial Withdrawal of Expert Disclosures Pursuant to C.R.C.P. 26(a)(2) and Response to Defendants’ Motion to Exclude Plaintiffs’ Experts Under Colo. R. Evid. 702
PLAINTIFFS’ NOTICE OF PARTIAL WITHDRAWAL OF EXPERT DISCLOSURES PURSUANT TO C.R.C.P. 26(a)(2) AND RESPONSE TO DEFENDANTS’ MOTION TO EXCLUDE PLAINTIFFS’ EXPERTS UNDER COLO. R. EVID. 702
Plaintiffs’ Response to Motion to Dismiss by the Retail Property Trust and Simon Entities
Plaintiffs’ response to motion to dismiss by the retail property trust and Simon entities.
Police Opinion, Motion in Limine to Preclude
Motion in limine to preclude police officer opinion
Premise liability and assault Complaint
Complaint against bar owner for failure to provide a safe environment for patron as well as complaint against unknown person who assaulted client
Product Liability Complaint
Strict Liability complaint for product liability
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.
Proposed Stipulated Jury Instructions – Personal Injury
PARTIES’ PROPOSED STIPULATED JURY INSTRUCTIONS
Punitive Damages, Motion for Leave to Amend to Add
Motion to Permit Amending Complaint to Allege Punitive Damages
Reply in Support of Motion for Pro Hac Vice Admission
Plaintiff’s reply in support of defendant’s motion for pro hac vice admission.Â
Response Appeal Brief
Response filed on an appeal, issue are excessive judgment and statements counsel made during closing