Examples of Motions and Responses

Post Trial Motions

  • Plaintiff's Response to Defendant's Motion for Remittitur, or, in the Alternative, Motion for New Trial [Select here]
    • Defendant's Motion for Remittitur [Select here]
    • Defendant's Response to Plaintiff's Response to Defendant's Motion for Remittitur [Select here]
  • Plaintiff's Opposition to Motion for J.N.O.V. or In the Alternative, Motion for a New Trial [Select here]
    • Defendant's Motion for J.N.O.V. or In the Alternative, Motion for a New Trial [Select here]
    • Plaintiff's Reply to Defendants Reply to Plaintiff's Opposition to Motion for J.N.O.V. or In the Alternative, Motion for a New Trial [Select here]
    • Defendant's Reply to Plaintiff's Opposition to Motion for J.N.O.V. or In the Alternative, Motion for a New Trial [Select here]
  • Plaintiff's Response to Defendant's Motion for a New Trial [Select here]
  • Plaintiff Response to Defendant's Motion to Revise Judgment [Select here]
  • Plaintiff's Motion for Judgment Notwithstanding the Verdict [Select here]
  • Plaintiff's Motion for JNOV (supplemental motion) [Select here]

Discovery Motions

  • Plaintiff's Motion to Compel Discovery Responses [Select here]
  • Plaintiff's Response to Defendant's Motion to Compel Defense Medical Exam [Select here]
  • Plaintiff's Motion to Compel Discovery [Select here]
  • Plaintiff's Response to Defendant's Motion to Compel Physical Examination [Select here]
  • Plaintiff's Motion to Compel Deposition [Select here]

Expert Motions

  • Plaintiff's Response to Motion to Protective Order for Expert Financial Records [Select here]
    • Defendant's Motion for Protective Order [Select here]
    • Judge's Order Granting Release of Expert's Financial Records [Select here]
  • Motion to Preclude Defendant's Experts [Select here]
  • Defendant's Motion to Compel a Physical Exam (citing IME "handbook") [Select here]
  • Defendant's Motion for a Protective Order from Second Trial Deposition [Select here]

Motions to Dismiss / Summary Judgment

  • Plaintiff's Motion for Judgment as a Matter of Law Regarding Defendant's Status as a Manufacturer of a Product [Select here]
  • Plaintiff's Response to Motion to Dismiss [Select here] (barred by Workers' Compensation Act)
  • Plaintiff's Motion for Partial Summary Judgment [Select here]
    • Plaintiff's Reply to Defendant's Response to Plaintiff's Motion for Summary Judgment [Select here]
  • Plaintiff's Response to Defendant's Motion to Dismiss [Select here]
    • Memorandum of Law in Support of Plaintiff's Motion for Summary Judgment, or in the Alternative, that Requests for Admission Be Deemed Admitted [Select here]
  • Plaintiff's Opposition to Defendant's Motion to Dismiss for Improper Venue [Select here]
  • Plaintiff's Response to Defendant's Motion to Dismiss [Select here]
  • Plaintiff's Opposition to Defendant's Motion for Summary Judgment [Select here]
  • Plaintiff's Opposition to Defendant's Motion for Summary Judgment (survival action/pre-impact fright case) [Select here]
  • Plaintiff's Opposition to Defendant's Motion for Summary Judgment (pedestrian car accident case) [Select here]
  • Plaintiff's Response to Defendant's Memo of Law on Incapacity Defense [Select here] (MS Word Version)
    • Defendant's Memorandum of Law on Incapacity Defense [Select here]
    • Defendant's Second Memorandum of Law on Incapacity Defense [Select here]
    • Court's Decision on Incapacity Defense Case [Select here]
  • Plaintiff's Opposition to Defendants' Motion to Dismiss for Personal Jurisdiction [Select here]
  • Plaintiff's Opposition to Defendants' Motion to Sever [Select here]

Motions in Limine

  • Motion in Limine to Exclude Testimony Regarding the Property Damage on the Vehicles [Select here]
  • Motion in Limine Regarding Subsequent Remedial Measures [Select here]
  • Motion in Limine to Preclude Defendant's Experts [Select here]
  • Motion in Limine Regarding Fact Witness [Select here]
  • Motion in Limine to Exclude Evidence Relating to Plaintiff's Arrest [Select here]
  • Motion in Limine to Exclude Tank Level Readings [Select here]
  • Motion in Limine to Exclude Opinion Testimony [Select here]
  • Motion in Limine to Exclude Evidence Concerning the Activities of Plaintiff After the Relevant Events in the Case [Select here]
  • Motion in Limine Regarding Other Parties Sued [Select here]
  • Motion in Limine to Prevent Defendant from Proffering Inconsistent Evidence at Trial [Select here]
  • Motion in Limine Regarding Ad Adamnum Clause [Select here]
  • Response to Motion in Limine to Exclude/Limit Expert's Opinion [Select here]
    • Defendant's Motion to Exclude/Limit Expert [Select here]

Pre-suit/Pre-Discovery Motions

  • Plaintiff's Motion for Service by Alternative Method [Select here]
  • Plaintiff's Motion to Consolidate Cases [Select here]
  • Plaintiff's Motion for Remand [Select here]


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See also Information for Lawyers Seeking To Refer Miller & Zois a Personal Injury Case (information for referring lawyers)