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Defendant’s Memorandum in Opposition to Plaintiff’s Motion for Temporary Injunction and Expedited Discovery
Defendant’s opposition brief in opposition to motion for temporary injunction and expedited discovery. Includes analysis of competing state laws. US District Court for the District of Minnesota.
Defendant’s Response to Government’s Motion to Admit Evidence of Defendant’s UCC Filings for 2011 and 2012
Defense response to Gvernment’s Motion to Admit specific evidence of a defendant’s UCC filings. Companion to the Motion to Admit Defendant’s UCC filings for 2011 and 2012, also on Lawyers Help Lawyers.
Defendant’s Proposed Voire Dire Questions
Proposed questions for jury selection from a criminal defendant in the US District Court for the Central District of California.
Defendant’s Sentencing Position Paper
Defendant’s Position memorandum on sentencing in a federal criminal case, Central District of California.
Government’s Motion to Admit Evidence of Defendant’s UCC Filings in 2011 and 2012
Federal prosecutor’s motion to admit specific acts of a criminal defendant. US District Court for the Central District of California.
Defendant’s Notice and Motion to Dismiss Counts One and Two
Defendant’s Notice and Motion to Dismiss two specific Counts in a federal criminal prosecution, on Constitutional Grounds. For the US District Court for the Western District of California.
Defendant’s Motion In Limine to Exclude Improper Opinion Testimony
Defendant’s Motion in Limine to exclude specific improper opinion testimony. Filed in the US istrict Court for the Western District of California, the motion, with exhibits, seeks to exclude improperly disclosed (or undisclosed) and otherwise impermissible opinion testimony under Rule 16(G).
Defendant’s Motion In Limine to Preclude Evidence of Uncharged Tax Years
Motion by a criminal defendant in the US District Court for the Western District of California to preclude the inclusion of specific evidence. In this case, to exclude evidence of tax filings for ax years not included in the Government’s charges.
Plaintiff’s Response and Objections to Notice to Take the Videotaped Deposition of and Subpoena Duces Tecum
PLAINTIFF’S RESPONSE AND OBJECTIONS TO NOTICE TO TAKE THE VIDEOTAPED DEPOSITION aND SUBPOENA DUCES TECUM
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
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.