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Motion for Judgment not withstanding the verdict or Motion for New Trial
Judgment was entered against my client. We filed a motion based on the evidence for a new trial or in the alternative a Motion Not Withstanding the Verdict. My client was held liability for Outrageous Conduct and emotion distress
Defendant Jury Instruction
Civil case Jury instruction with Mitigation of damages Defense
PLAINTIFFS’ RESPONSE TO DEFENDANT’S MOTION FOR CLARIFICATION OF ORDER RE: HYPOTHETICAL SETTLEMENT SCENARIOS
PLAINTIFFS’ RESPONSE TO DEFENDANT’S MOTION FOR CLARIFICATION OF ORDER RE: HYPOTHETICAL SETTLEMENT SCENARIOS
PLAINTIFFS’ RESPONSE IN OPPOSITION TO DEFENDANT’S THIRD MOTION IN LIMINE REGARDING RIGHTS VERSUS DUTIES
Plaintiff’s response in opposition to defendant’s third motion in limine regarding rights versus duties.
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S SIXTH MOTION IN LIMINE REGARDING
Plaintiff’s response to defendant’s sixth motion in limine regarding expert.
PLAINTIFFS’ RESPONSE IN OPPOSITION TO DEFENDANT’S FOURTH MOTION IN LIMINE REGARDING
Plaintiff’s response in opposition to defendant’s fourth motion in limine regarding expert.
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S FIRST MOTION IN LIMINE REGARDING HYPOTHETICAL SETTLEMENT SCENARIOS
Plaintiff’s response in opposition to defendant’s first motion in limine regarding hypothetical settlement scenarios.
PLAINTIFFS’ RESPONSE TO DEFENDANT’S FIFTH MOTION IN LIMINE REGARDING MILLER VALUATIONS
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PLAINTIFFS’ RESPONSE TO DEFENDANT’S FIFTH MOTION IN LIMINE REGARDING MILLER VALUATIONS. |
PLAINTIFFS’ REPLY IN SUPPORT OF MOTION TO AMEND COMPLAINT TO INCLUDE A PRAYER FOR EXEMPLARY DAMAGES
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PLAINTIFFS’ REPLY IN SUPPORT OF MOTION TO AMEND COMPLAINT TO INCLUDE A PRAYER FOR EXEMPLARY DAMAGES |
PLAINTIFFS PROPOSED JURY INSTRUCTIONS
Plaintiff’s proposed jury instructions.
PLAINTIFFS’ MOTION IN LIMINE RE: DEFENDANT’S “OPPORTUNITY TO SETTLE”
Plaintiff’s motion in limine Re: Defendant’s “opportunity to settle”
PLAINTIFFS’ MOTION FOR LEAVE TO FILE RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION TO BIFURCATE TRIAL OF LIABILITY AND DAMAGES ISSUES OUT OF TIME
Plaintiff’s motion for leave to file response in opposition to defendant’s motion to bifurcate trial of liability and damages issues out of time.
PLAINTIFFS’ MOTION FOR LEAVE TO FILE COMBINED RESPONSE TO DEFENDANT’S RULE 56 MOTIONS OUT OF TIME
Plaintiff’s motion to request that the court permit them to file their combined response to defendant’s rule 56 motions out of time.
PLAINTIFF’S FINAL MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT
Plaintiff requests that the court gran an extension of time to file their response to defendant’s motion for summary judgment.
PLAINTIFFS’ FINAL LIST OF REMAINING OBJECTIONS FROM PRESERVATION DEPOSITION OF — THAT REQUIRE RULINGS
Plaintiff states their final list of remaining objections from preservation deposition of expert that require rulings.