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Agreement for Legal Services
A quasi agreement of flat fee and contingent. I use in complex cases to make sure I get some of my fees covered even if there is no judgment
Defendant’s Motion for Summary Judgment Pursuant to C.R.C.P. Rule 56(b)
DEFENDANT’S MOTION FOR SUMMARY JUDGMENT PURSUANT TO C.R.C.P. RULE 56(b) Plaintiff has Suffered no Damages
Motion in Limine to Exclude Evidence
By failing to object to the timeline stated in the agreed to presumptive Case Management Order, Plaintiff is barred from introducing any evidence or calling any witnesses not disclosed prior to the October 19, 2008 discovery cut-off date
Defendant’s Designation for Non Parties at Fault
DEFENDANT’S DESIGNATION OF NON-PARTIES AT FAULT
Defendant’s First Set of Discovery Requests – Personal Injury
DEFENDANT’S FIRST SET OF DISCOVERY REQUESTS TO PERSONAL INJURY CASE
Affidavit of Attorney’s Fees & Costs on Motion to Compel
AFFIDAVIT OF ATTORNEY’S FEES AND COSTS on motion to compel
Medical Malpractice Complaint – Vicarious Liability
Medical malpractice complaint, Uninformed consent, Vicarious Liability
Plaintiff’s Response to Motion for New Trial – Medical Malpractice
PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION FOR NEW TRIAL
Plaintiff’s Notice of Errata Relative to her Election to Receive Immediate Payment
PLAINTIFF’S NOTICE OF ERRATA RELATIVE TO HER ELECTION TO RECEIVE IMMEDIATE PAYMENT OF THE PRESENT VALUE OF THE FUTURE DAMAGE AWARD IN A LUMP-SUM AMOUNT IN LIEU OF PERIODIC PAYMENTS
Defendant Trial Brief Regarding Recoverable Damages
DEFENDANT TRIAL BRIEF REGARDING RECOVERABLE DAMAGES
Plaintiff’s Memorandum of Law on Economic Damages
PLAINTIFF’S MEMORANDUM OF LAW ON ECONOMIC DAMAGES
Proposed Stipulated Jury Instructions – Personal Injury
PARTIES’ PROPOSED STIPULATED JURY INSTRUCTIONS
Opposition to Plaintiff’s Motion to Strike Defendant’s Affirmative Defense
DEFENDANT SECOND SUPPLEMENT TO OPPOSITION TO PLAINTIFF’S MOTION TO STRIKE DEFENDANT’S AFFIRMATIVE DEFENSE OF NONPARTY AT FAULT AND TO PRECLUDE INADMISSIBLE EVIDENCE CONCERNING ALLEGED NEGLIGENCE OR FAULT