Leonard Martinez
Leonard Martinez

Leonard Martinez

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Criminal Defense Legal Documents

MOTION TO CONTINUE TRIAL

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District Attorney submits a motion to continue the jury trial.

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MOTION TO AMEND

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District Attorney respectfully moves this Court to Amend Count XII, Assault in The First Degree, C.R.S. §18-3-202(1)(a), of the information filed against the defendant to be Assault in the First Degree, C.R.S. §18-3-202(1)(b).

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MOTION FOR NOTICE PURSUANT TO C.R.E. 404(B) [DEF – 4]

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Defendant’s request the Court order the prosecution to give notice of intent to admit evidence pursuant to C.R.E. 404(b).

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MOTION FOR NOTICE OF 404(b) EVIDENCE [11]

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Counsel moves for advance notice of any 404(b) evidence, and objects to the introduction of any such evidence at trial and requests a hearing

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MOTION FOR NON-TESTIMONIAL IDENTIFICATION EVIDENCE

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  MOTION FOR NON-TESTIMONIAL IDENTIFICATION EVIDENCE

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MOTION FOR EXPERT ENDORSEMENT AND DISCLOSURES [DEF – 3]

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MOTION FOR EXPERT ENDORSEMENT AND DISCLOSURES [DEF – 3]
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DEFENSE REQUEST FOR IN-PERSON TESTIMONY PURSUANT TO U.S. CONST. AMEND. VI AND C.R.S. §16-3-309(5) REGARDING TESTING AND CHAIN OF CUSTODY [DEF – 2]

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DEFENSE REQUEST FOR IN-PERSON TESTIMONY  PURSUANT TO U.S. CONST. AMEND. VI AND C.R.S. §16-3-309(5) REGARDING TESTING AND CHAIN OF CUSTODY [DEF – 2]

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Defendant’s Motion to Dismiss

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Defendant’s motion to dismiss the Second Amended Complaint on the ground that it fails to state a claim upon which relief can be granted. 

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Reply in Support of Motion for Pro Hac Vice Admission

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Plaintiff’s reply in support of defendant’s motion for pro hac vice admission. 

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

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Plaintiffs’ response to motion to dismiss by the retail property trust and Simon entities.

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Motion to Set Aside Dismissals or Alternatively Leave to File Third Amended Complaint and Jury Demand

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Motion to set aside dismissals or alternatively leave to file third amended complaint and jury demand.

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Motion to Consolidate – Personal Injury

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A motion to consolidate is a motion which seeks to combine two cases into one proceeding. It may be granted if the cases involve common questions of law or fact to be resolved. When the cases involve similar or related questions to be decided, the court may consolidate the cases in order to promote the efficient use of judicial resources.

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Motion for Leave to File Second Amended Complaint and Jury Demand

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Plaintiff’s motion for leave to file second amended complaint and jury demand. 

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First Amended Complaint and Jury Demand

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Plaintiffs pursuant to C.R.C.P. 25(a), respectfully submit the following First Amended Complaint and Jury Trial Demand.

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Defendants’ Joint Unopposed Motion for an Enlargement of Time to Designate Non-parties at Fault Pursuant to C.R.S. § 13-21-111.5 and Request for Ruling Forthwith

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DEFENDANTS’ JOINT UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO DESIGNATE NONPARTIES AT FAULT PURSUANT TO C.R.S. § 13-21-111.5 AND REQUEST FOR RULING FORTHWITH

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Defendant’s Unopposed Motion for an Enlargement of Time to Reply in Support of its Motion to Dismiss

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Defendant’s motion to  pursuant to the provisions of Rule 6(b) of the Colorado Rules of Civil Procedure to enlarge the specified period for replying to Plaintiffs’ Response to Motion to Dismiss by two weeks

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Defendants’ Response to New York Attorney’s Rule 221 Motion

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Defendant’s response to New York attorney’s rule 221 motion requesting permission to appear as counsel for Plaintiffs in this case. 

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Defendant’s Name’s Response in Opposition to Plaintiffs’ Motion to Set Aside Dismissals or Alternatively Leave to File a Third Amended Complaint and Jury Demand

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DEFENDANT’S NAME’S RESPONSE IN OPPOSITION TO PLAINTIFFS’ MOTION TO SET ASIDE DISMISSALS OR ALTERNATIVELY LEAVE TO FILE A THIRD AMENDED COMPLAINT AND JURY DEMAND

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Defendants’ Trial Brief – Personal Injury

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A trial brief sets forth the facts, evidence, and legal arguments the party intends to present at trial. A trial brief includes issue, which identify the issue raised by the facts of the client’s case. Rule , which identify the law(s) that controls the issue(s). Analysis, which explains how the rule of law apply to the issue(s). Conclusion, which is a summary of the legal analysis.

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Plaintiffs’ Motion in Limine to Admit into Evidence a Copy of the Notebook Written, Kept and Maintained by Shooter

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PLAINTIFFS’ MOTION IN LIMINE TO ADMIT INTO EVIDENCE A COPY OF THE NOTEBOOK WRITTEN, KEPT AND MAINTAINED BY SHOOTER

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Plaintiffs’ Motion in Limine to Preclude Defendants from Referencing Legally Incorrect Standard of Foreseeability Under Colorado’s Premises Liability Statue

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PLAINTIFFS’ MOTION IN LIMINE TO PRECLUDE DEFENDANTS FROM REFERENCING LEGALLY INCORRECT STANDARD OF FORESEEABILITY UNDER COLORADO’S PREMISES LIABILITY STATUTE

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