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PLAINTIFFS’ COMBINED RESPONSE TO DEFENDANT’S RULE 56 MOTIONS
PLAINTIFFS’ COMBINED RESPONSE TO DEFENDANT’S RULE 56 MOTIONS
PLAINTIFFS’ ADDITIONAL MOTION FOR ONE-DAY EXTENSION OF TIME
Plaintiff’s additional motion for one-day extension of time to file responses to defendant’s motion for summary judgement, motion for determination of law and motion for partial summary judgment as to the conduct of expert.Â
MOTION TO BIFURCATE TRIAL OF LIABILITY AND DAMAGES ISSUES
Defendant’s motion to move pursuant to C.R.C.P 42 to bifurcate the trial of liability issues from the trial of damages issues.Â
JOINT REQUEST FOR RULING ON OUTSTANDING ISSUE
Plaintiff and defendant’s joint request for ruling an outstanding issue.Â
DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME FOR SUBMISSION OF REPLY IN SUPPORT OF MOTION FOR CLARIFICATION
Defendant’s unopposed motion for extension of time to provide a reply in support of motion for clarification.Â
DEFENDANT’S THIRD MOTION IN LIMINE REGARDING RIGHTS VERSUS DUTIES
Defendant’s third motion in limine regarding rights versus duties states that pursuant to CRCP 121, counsel certifies conferral with counsel for plaintiff who object to the relief requested.Â
DEFENDANT’S SIXTH MOTION IN LIMINE REGARDING NAME
Defendant’s sixth motion in limine regarding the testimony of expert witness.Â
DEFENDANT’S SECOND MOTION IN LIMINE REGARDING PEV AND RESERVE INFORMATION
Defendant’s second motion regarding PEV or reserve information.
DEFENDANT’S RESPONSE TO PLAINTIFFS’ MOTION TO AMEND COMPLAINT TO INCLUDE A PRAYER FOR EXEMPLARY DAMAGES
Defendant’s response to plaintiff’s motion to amend complaint to include a prayer for exemplary damages.Â
DEFENDANT’S REQUEST FOR RECONSIDERATION OF COURT’S ORDER RE: DEPOSITION
Defendant’s requests the court to reconsider objections which were upheld by Division 3 in their review of the deposition of expert.Â
DEFENDANT’S REPLY TO PLAINTIFFS’ RESPONSE TO FIRST MOTION IN LIMINE REGARDING HYPOTHETICAL SETTLEMENT SCENARIOS
Defendant’s reply to plaintiff’s response to the first motion regarding hypothetical settlement scenarios.Â
DEFENDANT’S REPLY IN SUPPORT OF THIRD MOTION IN LIMINE REGARDING RIGHTS VERSUS DUTIES
Defendant’s reply in support of third motion regarding rights versus duties owed by defendant.Â
DEFENDANT’S REPLY IN SUPPORT OF SIXTH MOTION IN LIMINE REGARDING NAMES
Defendant’s reply in support of their sixth motion regarding the testimony of the expert. This motion asks the court to prevent plaintiffs from introducing evidence, testimony, or opinion from the Judge.
DEFENDANT’S REPLY IN SUPPORT OF SECOND MOTION IN LIMINE REGARDING PEV AND RESERVE INFORMATION
Defendant’s reply in support of second motion regarding the prevention of plaintiff from introducing evidence, testimony, or argument regarding the pure exposure value (PEV) or reserve information for the expert witness.Â