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MOTION TO SUPPRESS: THE WARRANT
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MOTION TO SUPPRESS: THE WARRANT RELIED UPON TO SEARCH DEFENDANT’S HOME WAS UNCONSTITUTIONAL BECAUSE IT WAS AUTHORIZED WITHOUT PROBABLE CAUSE, DID NOT IDENTIFY THE OBJECT OF THE SEARCH NOR THE PREMISES TO BE SEARCHED WITH SPECIFICITY, AND WHILE EXECUTING THE WARRANT, THE POLICE WENT BEYOND THE SCOPE ALLOWED BY THE SEARCH WARRANT, AND COLLECTED NUMEROUS ITEMS NOT AUTHORIZED BY THE WARRANT [16]. |
MOTION TO SUPRESS AUTOPSY AS A SANCTION [14]
Defendant’s motion to suppress autopsy because the defense counsel was allowed to present during the autopsy in this matter, violating the order of the court, the Colorado Bar Association Ethics Opinion, and violating C.R.C.P. 16.Â
PEOPLE’S MOTION FOR PROTECTIVE ORDER UNDER RULE 16 III (d)
PEOPLE’S MOTION FOR PROTECTIVE ORDER UNDER RULE 16 III (d)Â
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PEOPLE’S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE ANSWER BRIEF
People’s unopposed motion for enlargement of time to file answer brief.Â
PEOPLE’S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE ANSWER BRIEF
People’s unopposed motion for enlargement of time to file answer brief.Â
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE OPENING BRIEF
Defendant’s attorney files an unopposed motion for extension of time to file opening brief.Â
Unopposed Motion for Stay of Execution of Sentence
Defendant’s attorney requests the court to enter an order staying the execution of the sentence in this matter until such time as the merits of the appeal at all levels has been determined.Â
DEFENDANT’S EMERGENCY MOTION FOR TELEPHONIC HEARING
Defendant’s counsel certifies that he has attempted to contact plaintiff’s counsel several times and received no response prior to filing this motion. Defendant filed a motion in Limine regarding hypothetical settlement scenarios.Â
DEFENDANT’S FIFTH MOTION IN LIMINE REGARDING NAME VALUATIONS
Defendant’s fifth motion in limine regarding valuations performed by a person that is an expert witness for plaintiff.Â
DEFENDANT’S FOURTH MOTION IN LIMINE REGARDING NAME
Defendant’s fourth motion in limine regarding conduct, advice, actions or inaction of plaintiff’s witness.Â
DEFENDANT’S MOTION FOR CLARIFICATION REGARDING THE COURT’S ORDER ON ITS FIRST MOTION IN LIMINE REGARDING HYPOTHETICAL SETTLEMENT SCENARIOS
Defendant’s motion for clarification regarding the court’s order on defendant’s first motion in limine regarding the hypothetical settlement scenarios.Â
DEFENDANT’S MOTION FOR DETERMINATION OF LAW
Defendant’s pursuant to C.R.C.P 56, makes the motion for determination of law: pursuant to C.R.C.P. 121, undersigned counsel certifies conferral with counsel for plaintiff who objects to the relief requested in this motion.Â
DEFENDANT’S MOTIONS FOR DIRECTED VERDICT
Defendant’s motion for directed verdict under C.R.C.P 50.
DEFENDANT’S MOTION FOR PARTIAL SUMMARY JUDGMENT AS TO THE CONDUCT OF NAME
Defendant’s motion for partial summary judgment, as to the conduct of plaintiff’s witness, follows the pursuant to C.R.C.P 121, counsel certifies conferral with counsel for plaintiff who objects to the relief requested in this motion. Â