Leonard Martinez
Leonard Martinez

Leonard Martinez

  • Colorado, United States (US)
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    Plaintiffs’ Motion in Limine to Preclude Defendants from Referencing Movie Theater Industry Security Standard, Protocols or Practices

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    PLAINTIFFS’ MOTION IN LIMINE TO PRECLUDE DEFENDANTS FROM REFERENCING MOVIE THEATER INDUSTRY SECURITY STANDARDS, PROTOCOLS OR PRACTICES

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    Plaintiffs’ Motion in Limine to Preclude Defendants From Referencing the Biographical Backgrounds of Counsel

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    PLAINTIFFS’ MOTION IN LIMINE TO PRECLUDE DEFENDANTS FROM REFERENCING THE BIOGRAPHICAL BACKGROUNDS OF COUNSEL

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    Defendants’ Combined Motions in Limine

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    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.

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    Response to Plaintiffs’ Motion to Exclude Defendants’ Experts

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     Plaintiff’s motion to limit the testimony of four of the defendants’ experts. 

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    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

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    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

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    Soudani Plaintiffs’ and Defendants’ Joint Brief on Jury Questionnaires

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    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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    Defendants’ Motion for Partial Judgment on the Pleadings on Issue Preclusion Affirmative Defense

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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

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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

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    Motion for Reconsideration Pursuant to Colo. R. CIV. PRO. 121 § 1-15(11)

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    Plaintiffs’ Brief in Opposition to a Stay of Litigation

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    Plaintiff’s brief in opposition to a stay of litigation, submit this brief in opposition to a stay proceedings. 

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    Defendants’ Brief Regarding a Partial Stay

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    DEFENDANTS’ BRIEF REGARDING A PARTIAL STAY.

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    Plaintiffs’ Brief on the Issue of Bifurcation

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    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.

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    Defendants’ Motion for a Protective Order to Sequence Discovery on Liability

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    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.

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    Plaintiffs’ Opposition to Defendants’ Motion to Coordinate Depositions

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    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. 

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    Defendants’ Motion to Coordinate Depositions

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    Defendant’s motion to move to coordinate the depositions between the related cases currently pending in two district courts. 

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    Defendants’ Notice of Removal – Personal Injury

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    Defendant’s notice of removal to remove the instant case to the United States District Court for the District of Colorado.  A notice of removal is signed by the defendants and filed in federal court to begin the process of transferring the civil action from state court to federal court. Promptly after the filing of such notice of removal of a civil action the defendant or defendants shall give written notice thereof to all adverse parties and shall file a copy of the notice with the clerk of such State court, which shall effect the removal and the State court shall proceed no further.

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    Defendants’ Joinder in Support of Defendants’ Names’ Motion for Summary Judgement and Request for Forthwith Ruling

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    DEFENDANTS’ JOINDER IN SUPPORT OF DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT AND REQUEST FOR FORTHWITH RULING. 

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    The Defendant’s Motion For Summary Judgement in Soudani and Request for Ruling Forthwith

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    Plaintiffs’ Response to Motion to Dismiss by the Retail Property Trust and Simon Entities

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    Plaintiff’s Motion to Dismiss Plaintiffs’ Second Amended Complaint by the Retail Property Trust and Simon entities. 

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    Plaintiffs’ Opposition to Motion to Dismiss Defendants

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    Plaintiff’s opposition to defendant’s motion to dismiss the complaint.

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    Defendants’ Motion to Dismiss

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    Defendant’s motion to dismiss  people from the lawsuit on the grounds that the complaint fails to state a claim upon which relief can be granted.

    Reasons for Filing a Motion to Dismiss include, lack of subject matter jurisdiction, lack of personal jurisdiction, improper venue, failure to state a claim for which relief can be granted, insufficient service of process, passing of statute of limitations, motion for summary judgment and motion for default judgment.
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