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Motion to Strike Witnesses
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Respondent, §
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Movant. §
MOVANT’S MOTION TO STRIKE RESPONDENT’S WITNESSES
CERTIFICATE OF CONFERENCE
On the _____ day of ____________ 20___, a conference was held with ________________, the attorney for _____________, regarding the merits of this Motion. Agreement could not be reached. Therefore, this Motion is presented to the Court for determination.
MOTION
NOW COMES ____________________, ____________ in the above entitled and numbered cause, and files this its ______________’s (hereafter “Movant”) Motion to Strike Respondent’s Witnesses, and in support thereof would show the Court as follows:
I. OBJECTIONS TO WITNESSES TIMELY SUBMITTED
Movant timely filed its Objections to Plaintiff’s (hereafter “Respondent”) Witnesses as required by the Court’s Scheduling Order. See, Objections to Respondent’s Exhibits and Witnesses and exhibits thereto, on file with the Court. Among the objections urged by Movant were objections:
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to witnesses ______________, _______________ and _______________ as being insufficiently identified as required by the Rules of Civil Procedure;
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to the testimony of ______________, _______________ and _______________ under Federal Rule of Evidence 404 and Federal Rule of Evidence 602;
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to using the depositions of _________________, _______________ and _______________ because Respondent has not complied with Federal Rule of Civil Procedure 26 and/or the Court’s Scheduling Order;
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to the testimony of Respondent, since ____________ was never identified in response to interrogatories. Respondent’s pre-trial disclosure of ___________ as a witness, more than ________ after the discovery cutoff, is untimely. Further, because of the late identification, Movant did not have the opportunity to depose ____________ prior to the deposition cutoff deadline.
II. MOTION TO STRIKE ______________, ______________, AND ____________
This motion is made to strike witnesses ______________, _______________ and _______________ on the grounds outlined above and in Movant’s Objections, based on the pleadings and papers on file in this cause and the documents attached to Movant’s Objections, and as further detailed in the Brief filed herewith in support of the Objections and this Motion.
III. IT IS IN THE INTEREST OF
JUSTICE TO DECIDE THIS MATTER NOW
The trial in this matter is...
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- Trial
- Defendant's limine motion in employment cases in general (fed)
- Juror questionnaire for use by defendant in employment case (state and federal)
- Unopposed/opposed motion and brief for use of juror questionnaire (state & fed)
- Order granting use of juror questionnaire (state & fed)
- Direct Examination Outline: Defendant's H.R. Manager
- Direct examination outline: plaintiff's economist in employment (and personal injury) cases
- Trial brief: evidence of similar incidents is relevant and admissible
- Plaintiff's limine motion in employment cases in general (state)
- Defendant's limine motion for employment cases involving AGE/RACE (FED)
- Plaintiff's Jury Instructions and Jury Charge: Whistleblower Case (State Court)
- Defendant's Proposed Questions and Instructions to the Jury and Memorandum of Law: Age (Reduction In Force) and Race Discrimination Case (Federal Court)
- Defendant's proposed voir dire questions for judge in age, race & rif cases (fed & state)
- Defendant's Proposed Voir Dire: Age, Race (Fed.)
- Defendant's Trial Brief: F.I., Breach of Contract, Handbook, Mitigation
- Stipulation: Plaintiff's Damages
- Stipulation: plaintiff's reasonable & necessary attorney's fees
- Stipulation: corporation assumes liability, if any, for subsidiary or related companies in dispute involving current or former employee (state/federal)
- Direct: Treating Psychologist For Plaintiff
- Order on motion to strike witnesses and objections to fact witnesses (fed)
- Brief in support of motion to strike and objections to testimony of fact witnesses (FED)
- Motion to Strike Witnesses
- Juror Personal History Questionnaire
- Defendant's jury instructions & questions: sex discrimination, retaliation and FLSA violations (fed.)
- Sample Jury Charge-Non-Compete Case
- Defendant's requested jury instructions and written interrogatories
- Juror Questionnaire - Gender Discrimination and Breach of Contract
- Plaintiff's Jury Demand
- Plaintiff's Motion in Limine - Gender Discrimination Case - State Court
- Plaintiff's Requested Jury Instructions and Questions - Gender Discrimination and Breach of Contract
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