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Defendants Company Trial Brief on Improper Argument of Defendant’s ongoing Employment
DEFENDANT COMPANY TRIAL BRIEF ON IMPROPER ARGUMENT OF DEFENDANT’S ONGOING EMPLOYMENT in auto accident case
Plaintiff’s Memorandum Brief in Opposition to Defendant, M.D.’S C.R.M. 7 Petition for Review of Magistrate’s Order
PLAINTIFF’S MEMORANDUM BRIEF IN OPPOSITION TO DEFENDANT , M.D.’S C.R.M. 7 PETITION FOR REVIEW OF MAGISTRATE’S ORDER
Defendant Company Trial Brief Re: Negligent Entrustment Claim
DEFENDANT COMPANY TRIAL BRIEF RE: NEGLIGENT ENTRUSTMENT CLAIM in auto accident
Defendant’s Initial Rule 26 Disclosures – Personal Injury
A party must make its initial disclosures based on the information then reasonably available to it. In addition to the disclosures required by Rule 26(a)(1), a party must disclose to the other parties the identity of any witness it may use at trial to present evidence under Federal Rule of Evidence 702, 703, or 705. Appendix A to these disclosures identifies those individuals who may have discoverable information relevant to disputed facts alleged with particularity in the pleadings.
Motion to Preclude Client from Introducing Evidence or Testimony – Plaintiff was not Informed of Her Right to Undergo Testing
PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION IN LIMINE TO PRECLUDE PLAINTIFF FROM ARGUING, OR INTRODUCING EVIDENCE OR TESTIMONY, THAT PLAINTIFF WAS NOT INFORMED OF HER RIGHT ON AUGUST 1, 2012, TO UNDERGO TESTING TO DEFINITIVELY RULE OUT THE POSSIBILITY OF INFECTION
Response to Defendant’s Motion to Prohibit Plaintiff from Asking Any Medical Expert Whether the Conduct of Physicians, was “Foreseeable”
PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION IN LIMINE TO PROHIBIT PLAINTIFF FROM ASKING ANY MEDICAL EXPERT WHETHER THE CONDUCT OF , OR OTHER UCH PHYSICIANS, WAS “FORESEEABLE
Defendant’s Motion for Leaving to Conduct Ex Parte Meetings with some of Plaintiff’s Treating Health Care Providers
DEFENDANT’S MOTION FOR LEAVE TO CONDUCT EX PARTE MEETINGS WITH SOME OF PLAINTIFF’S TREATING HEALTH CARE PROVIDERS
Plaintiff’s Motion to Exclude Standard of Care Opinions by Name, M.D. Pusuant to C.R.E. 702
PLAINTIFF’S MOTION TO EXCLUDE STANDARD OF CARE OPINIONS BY NAME, M.D. PURSUANT TO C.R.E. 702
Motion to Confess Judgment on Promissory Note, Dismiss all Related Claims, and Request for Forthwith Ruling
MOTION TO CONFESS JUDGMENT ON PROMISSORY NOTE AND DISMISS ALL RELATED CLAIMS AND REQUEST FOR FORTHWITH RULING 2. Plaintiffs therefore respectfully request that the Court dismiss with prejudice all claims related to the Note, including Plaintiffs’ claim for Negligent Misrepresentation against Defendant– Water Shares (Plaintiffs’ Third Amended Complaint, Fifth Claim for Relief) and the Defendants’ Counterclaim for Breach of Contract under the terms of the Note (Defendants’ Answer, Jury Demand, and Counterclaim, First and Second Claims for Relief in the Counterclaim).
Response to Defendant’s Motion to Exclude any Evidence of Medical Expense Payments from any Collateral Source
PLAINTIFFS’ RESPONSE TO DEFENDANT’S MOTION IN LIMINE MOTION IN LIMINE TO EXCLUDE ANY EVIDENCE OF MEDICAL EXPENSE PAYMENTS FROM ANY COLLATERAL SOURCE
Response to Plaintiff’s Shreck Motion to Preclude Testimony of Doctor
Defendant RESPONSE TO PLAINTIFFS’ SHRECK MOTION IN LIMINE TO PRECLUDE THE TESTIMONY OF DR. A
Plaintiff’s Motion in Limine – Medical Malpractice
PLAINTIFF’S MOTIONS IN LIMINE
A. Unopposed Motion in Limine to Preclude any Evidence or Argument Regarding the Alleged Consequences of a Damages Award in This Lawsuit or Any Other Medical Malpractice Lawsuit
B. Unopposed Motion in Limine to Preclude Any Arguments or Inferences That Plaintiff is Bringing Her Claims Simply to Win the Lottery or Otherwise Roll the Dice on Litigation
E. Motion in Limine to Preclude Any Evidence, Testimony, Argument, or Suggestion of Any Alleged Comparative Fault of Plaintiff or Failure to Mitigate Damages by Plaintiff.
A. Motion in Limine to preclude any expert witness from offering opinions or testimony outside the scope of their previously disclosed opinions.
Plaintiff’s Motion to Restrict Access
PLAINTIFF’S MOTION TO RESTRICT ACCESS to Plaintiff’s attorney medical records.
Plaintiff’s Motion to Introduce Summaries into Evidence at Trial
PLAINTIFF’S MOTION TO INTRODUCE SUMMARIES INTO EVIDENCE AT TRIAL
Plaintiff’s Motion to Compel Production of Documents and for Expedited Hearing
PLAINTIFF’S MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND FOR EXPEDITED HEARING in an employment Title vII case