Free Proposed Jury Instructions - District Court of Colorado - Colorado

Case 1:03-cv-02073-WDM-KLM

Document 226

Filed 01/03/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 03-CV-02073-WDM-PAC

ROBERTA PULSE, TONYA HOUSE, Plaintiffs, v. THE LARRY H. MILLER GROUP, Defendant. ______________________________________________________________________________ PLAINTIFFS' PROPOSED JURY INSTRUCTIONS ______________________________________________________________________________ Plaintiffs respectfully submit the following Proposed Jury Instructions: During a pre-trial conference, this Court requested the parties submit jury instructions by today at 1:00 p.m. The Court encouraged the parties to submit joint instructions with objections noted. The parties' counsel had been working on stipulated jury instructions, and had agreed to exchange their respective jury instructions prior to the Court's deadline of 1:00 p.m. today. Plaintiffs' counsel submitted its proposed jury instructions to Defendant's counsel. Unfortunately, Defendant has not submitted its additional jury instructions as of this filing. Therefore, in order to comply with the Court's order, Plaintiffs hereby submits the attached jury instructions. Plaintiffs presently submit five jury instructions. Plaintiffs have not numbered these instructions, as it will be necessary to merge them with Defendant's jury instructions. In addition to the attached instructions, Plaintiffs stipulate to Jury Instructions 4-13

Case 1:03-cv-02073-WDM-KLM

Document 226

Filed 01/03/2006

Page 2 of 2

of Defendant's jury instructions previously submitted on December 22, 2005. Plaintiffs respectfully request the Court to allow them an opportunity to object to jury instructions subsequently filed and/or proposed by Defendant, and to add additional instructions as necessitated. Respectfully submitted this 3rd day of January, 2006. W.C. Traylor & Associates, LLC s/Whitney Traylor ______________________________________ Whitney C. Traylor W.C. Traylor & Associates, LLC 700 E. 24th Ave., #1 Denver, CO 80205 Telephone: 303-321-1862 Facsimile: 303-837-1214 Email: [email protected] Kimberlie K. Ryan Ryan Law Firm, LLC 283 Columbine St., #157 Denver, CO 80206 Telephone: 303-355-0639 Facsimile: 303-355-3020 Email: [email protected] ATTORNEYS FOR PLAINTIFFS CERTIFICATE OF SERVICE I certify that on the 3rd day of January, 2006, I electronically filed Plaintiffs' Proposed Jury Instructions with the Clerk of Court using the CM/ECF system, which will send notification to the following addresses to counsel of record: Judy Holmes, [email protected] Steven M. Gutierrez, [email protected] Christopher M. Leh, [email protected]

s/ Whitney C. Traylor