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Defendants’ Combined Motions in Limine
Defendants motion to exclude from trial testimony and evidence of (1) expiration of the statute of limitations against; (2) Defendants’ budget, profit, and bonus policies; (3) irrelevant previous crimes; (4) Defendants’ firearm policy; (5) subsequent remedial measures; (6) Defendants’ alleged failure to produce evidence; (7) Plaintiffs’ injuries; (8) insurance coverage; and (9) placing the jury into the Plaintiffs’ position.
Response to Plaintiffs’ Motion to Exclude Defendants’ Experts
 Plaintiff’s motion to limit the testimony of four of the defendants’ experts.Â
Plaintiffs’ Notice of Partial Withdrawal of Expert Disclosures Pursuant to C.R.C.P. 26(a)(2) and Response to Defendants’ Motion to Exclude Plaintiffs’ Experts Under Colo. R. Evid. 702
PLAINTIFFS’ NOTICE OF PARTIAL WITHDRAWAL OF EXPERT DISCLOSURES PURSUANT TO C.R.C.P. 26(a)(2) AND RESPONSE TO DEFENDANTS’ MOTION TO EXCLUDE PLAINTIFFS’ EXPERTS UNDER COLO. R. EVID. 702
Soudani Plaintiffs’ and Defendants’ Joint Brief on Jury Questionnaires
Plaintiffs and Defendants submit this brief on the Court’s ability to permit counsel to remove jury questionnaires from the courthouse grounds.
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Plaintiffs’ Motion to Exclude Defendants’ Designated Experts Pursuant to C.R.E. 702
Defendant’s motion for an Order excluding at the trial of this matter the testimony of four purported experts proffered by Defendants
Motion for Order Authorizing Production of Records Pursuant to Colo. R. CIV. P. 45(c)(2)(B) and Request for Expedited Ruling
MOTION FOR ORDER AUTHORIZING PRODUCTION OF RECORDS PURSUANT TO COLO. R. CIV. P. 45(c)(2)(B) AND REQUEST FOR EXPEDITED RULING
Plaintiffs’ Brief in Opposition to a Stay of Litigation
Plaintiff’s brief in opposition to a stay of litigation, submit this brief in opposition to a stay proceedings.Â
Defendants’ Brief Regarding a Partial Stay
DEFENDANTS’ BRIEF REGARDING A PARTIAL STAY.
Plaintiffs’ Brief on the Issue of Bifurcation
Plaintiff provides the instant brief on the issue of whether bifurcation of the liability and damages phases of the trial of this action is necessary. Bifurcation is a judge’s ability in law to divide a trial into two parts so as to render a judgment on a set of legal issues without looking at all aspects. In a bifurcated case, the issues of liability and damages are decided separately. The trier of fact will only decide the issue of liability at the first trial. If the defendant is not found to be liable, then there will be no damages trial.
Defendants’ Motion for a Protective Order to Sequence Discovery on Liability
A motion for protective order refers to a party’s request that the court protect it from potentially abusive action by the other party. Such a request is often made in relation to discovery, as when one party seeks discovery of the other party’s trade secrets. A protective order from discovery protects the person who would otherwise have to provide discovery (e.g. answer interrogatories, answer deposition questions on a subject, provide documents responsive to a request for production of documents, to allow someone to inspect premises, or to participate in a forensic medical.
Unopposed Motion for Leave to File First Amended Complaint and Jury Demand
Plaintiff’s unopposed motion for leave to file first amended complaint and jury demand.
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Plaintiffs’ Opposition to Defendants’ Motion to Coordinate Depositions
Defendant’s motion to have Plaintiffs action to coordinate the depositions of defendant’s employees with separate federal court cases all to the prejudice of plaintiffs herein.Â
Defendants’ Motion to Coordinate Depositions
Defendant’s motion to move to coordinate the depositions between the related cases currently pending in two district courts.Â