Plaintiffs’ Motion in Limine to Preclude Defendants from Referencing Movie Theater Industry Security Standard, Protocols or Practices
PLAINTIFFS’ MOTION IN LIMINE TO PRECLUDE DEFENDANTS FROM REFERENCING MOVIE THEATER INDUSTRY SECURITY STANDARDS, PROTOCOLS OR PRACTICES
Plaintiffs’ Motion in Limine to Preclude Defendants From Referencing the Biographical Backgrounds of Counsel
PLAINTIFFS’ MOTION IN LIMINE TO PRECLUDE DEFENDANTS FROM REFERENCING THE BIOGRAPHICAL BACKGROUNDS OF COUNSEL
Defendantsā Combined Motions in Limine
Defendants motion to exclude from trial testimony and evidence of (1) expiration of the statute of limitations against; (2) Defendantsā budget, profit, and bonus policies; (3) irrelevant previous crimes; (4) Defendantsā firearm policy; (5) subsequent remedial measures; (6) Defendantsā alleged failure to produce evidence; (7)Ā Plaintiffsā injuries; (8) insurance coverage; and (9) placing the jury into the Plaintiffsā position.
Response to Plaintiffsā Motion to Exclude Defendantsā Experts
Ā Plaintiff’s motion to limit the testimony of four of the defendants’ experts.Ā
Plaintiffsā Notice of Partial Withdrawal of Expert Disclosures Pursuant to C.R.C.P. 26(a)(2) and Response to Defendantsā Motion to Exclude Plaintiffsā Experts Under Colo. R. Evid. 702
PLAINTIFFSā NOTICE OF PARTIAL WITHDRAWAL OF EXPERT DISCLOSURES PURSUANT TO C.R.C.P. 26(a)(2) AND RESPONSE TO DEFENDANTSā MOTION TO EXCLUDE PLAINTIFFSā EXPERTS UNDER COLO. R. EVID. 702
Soudani Plaintiffsā and Defendantsā Joint Brief on Jury Questionnaires
Plaintiffs and Defendants submit this brief on the Courtās ability to permit counsel to remove jury questionnaires from the courthouse grounds.
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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.Ā
Defendants’ Brief Regarding a Partial Stay
DEFENDANTSā 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 aĀ bifurcatedĀ case, theĀ issuesĀ of liability and damages are decided separately. The trier of fact will only decide theĀ issueĀ 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 theĀ courtĀ protect it from potentially abusive action by the other party. Such a request is often made in relation toĀ discovery, as when one party seeksĀ discovery of the other party’s trade secrets. AĀ protective orderĀ fromĀ discoveryĀ protects the person who would otherwise have to provideĀ 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.
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.Ā
Defendants’ Motion to Coordinate Depositions
Defendant’s motion to move to coordinate the depositions between the related cases currently pending in two district courts.Ā
Defendants’ Notice of Removal – Personal Injury
Defendant’s notice of removal to remove the instant case to the United States District Court for the District of Colorado.Ā AĀ notice of removalĀ is signed by theĀ defendants and filed in federal court to begin the process of transferring the civil action from state court to federal court. PromptlyĀ afterĀ the filing of suchĀ notice of removalĀ of a civil action the defendant or defendants shall give writtenĀ noticeĀ thereof to all adverse parties and shall file a copy of theĀ noticeĀ with the clerk of such State court, which shall effect theĀ removal and the State court shall proceed no further.
Defendants’ Joinder in Support of Defendants’ Names’ Motion for Summary Judgement and Request for Forthwith Ruling
DEFENDANTSā JOINDER IN SUPPORT OF DEFENDANTSā MOTION FOR SUMMARY JUDGMENT AND REQUEST FOR FORTHWITH RULING.Ā
Plaintiffs’ Response to Motion to Dismiss by the Retail Property Trust and Simon Entities
Plaintiff’sĀ Motion to Dismiss Plaintiffsā Second Amended Complaint by the Retail Property Trust and Simon entities.Ā
Plaintiffs’ Opposition to Motion to Dismiss Defendants
Plaintiff’s opposition to defendant’s motion to dismiss the complaint.
Defendants’ Motion to Dismiss
Defendant’s motion to dismissĀ people from the lawsuit on the grounds that the complaint fails to state a claim upon which relief can be granted.