Free Proposed Jury Instructions - District Court of Colorado - Colorado

Case 1:01-cv-02089-MSK-CBS

Document 250

Filed 05/08/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 01-cv-2089-MSK-CBS DEAN A. BRAMLET, M.D., Plaintiff, v. ASPEN VALLEY HOSPITAL DISTRICT, Defendant. ______________________________________________________________________________ JOINT PROPOSED JURY INSTRUCTIONS AND VERDICT FORM ______________________________________________________________________________ The parties, through their undersigned counsel, hereby submit their joint proposed Jury Instructions and Verdict Form: 1. The parties have exchanged proposed jury instructions and have discussed the

jury instructions as they relate to the claims to be presented at trial. The parties will continue to confer on these issues and will attempt to reach a consensus on many of the disputed instructions. 2. the claims. However, the parties have substantial disagreement as to the law which applies to The parties, therefore, submit separate instructions, with supporting authority,

anticipating a ruling from the Court as to the law which applies to these claims. 3. The parties attach their separate proposed instructions, Plaintiff's, Exhibit A, and

Defendant's, Exhibit B, as well as their proposed verdict forms, Plaintiff's Exhibit C and Defendant's Exhibit D. Respectfully submitted this 8th day of May 2006.

s/Sander N. Karp

Case 1:01-cv-02089-MSK-CBS

Document 250

Filed 05/08/2006

Page 2 of 2

Sander N. Karp Leavenworth & Karp, PC P.O. Drawer 2030 201 14th Street, Suite 200 Glenwood Springs, Colorado 81601 Telephone: (970) 945-2261 e-mail: [email protected] ATTORNEYS FOR PLAINTIFF

s/Colleen M. Rea Colleen M.Rea, Esq. #024960 FORD & HARRISON LLP 1675 Broadway, Suite 2150 Denver, CO 80202 Telephone: (303) 592-8860 Facsimile: (303) 592-8861 E-Mail: [email protected] ATTORNEYS FOR DEFENDANT

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