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HomeMy WebLinkAbout2020CV30363 - Stuward Cross And Katrina Richman V. City Of Fort Collins - 039 - Plaintiffs' Preliminary Exhibit List COME NOW the Plaintiffs, by and through their counsel, and hereby submits Plaintiffs’ Preliminary List of Exhibits and states as follows: Exhibit Number Description Stipulated Objected Traffic Accident Report Property Damage Photos Katrina Richman Audio Recording Glenn Vigil Audio Recording Concentra, Medical Record, Stuward Cross Concentra, Billing Record, Stuward Cross Salud Clinic, Medical Record, Stuward Cross Salud Clinic, Medical Record, Stuward Cross UC Health, Medical Record, Stuward Cross UC Health, Billing Record, Stuward Cross Colorado Clinic Records, Medical Record, Stuward Cross Colorado Clinic Records, Billing Record, Stuward Cross DISTRICT COURT, LARIMER COUNTY, STATE OF COLORADO Court Address: 201 Laporte Ave. Fort Collins, CO 80621 Plaintiffs: STUWARD CROSS AND KATRINA RICHMAN v. Defendant: THE CITY OF FORT COLLINS, STATE OF COLORADO Court Use Only Attorneys for Plaintiffs: Laura Browne, # 46673 Ashley Fridovich, # 47538 WILHITE, ROSE, MCCLURE &, SAWAYA P.C. 1600 Ogden Street Denver, CO 80218 Phone Number: (303) 839-1650 FAX Number: (303) 832-7102 E-mail: lbrowne@sawayalaw.com afridovich@sawayalaw.com Case Number: 2020CV30363 Division: 5A PLAINTIFFS PRELIMINARY EXHIBIT LIST Colorado in Motion, Medical Record, Stuward Cross Colorado in Motion, Billing Record, Stuward Cross Workers Compensation Records, Stuward Cross 2021-5-28 Cross Wage Loss Chart, Stuward Cross Cross 2017 Joint Federal Tax Return, Stuward Cross Cross 2018 Joint Federal Tax Return, Stuward Cross Cross 2020 Joint Federal Tax Return, Stuward Cross Fort Collins MRI, Billing Record, Stuward Cross UCHealth Family Medicine, Medical Record, Katrina Richman UCHealth Family Medicine, Billing Record, Katrina Richman UCHealth Poudre Valley EMS, Medical Records, Katrina Richman UCHealth Poudre Valley EMS, Billing Records, Katrina Richman Rocky Mountain Physical Therapy, Medical Records, Katrina Richman Rocky Mountain Physical Therapy, Billing Records, Katrina Richman Front Range Pain Medicine, Medical Record, Katrina Richman Prior UCHealth Poudre Valley, Medical Records, Katrina Richman Prior UCHealth Family Medicine Center, Medical Records, Katrina Richman Prior Rocky Mountain Physical Therapy, Medical Records, Katrina Richman Prior Northern Colorado Pain, Medical Records, Katrina Richman Prior Integrated Center for Health, Medical Records, Katrina Richman Prior UCHealth Imaging, Medical Records, Katrina Richman Integration Mental Health, Medical Record, Katrina Richman Priors Summitstone, Medical Record, Katrina Richman Family Physicians Johnstown, Medical Record, Katrina Richman Deposition Transcript of Stuward Cross Deposition Transcript of Katrina Richman Report of Dr. John Hughes for Stuward Cross Report of Dr. John Hughes for Katrina Richman Demonstrative Number 1. Any demonstrative exhibits The parties reserve the right to use the following additional exhibits: 1. Any document identified in any C.R.C.P. 26(a)(1) Disclosures, C.R.C.P. 26(a)(2) Expert Disclosures, or in discovery, or identified in any Witness or Exhibit List. 2. Any and all documents or tangible things necessary for rebuttal or impeachment. 3. Any and all documents referred to or made an exhibit for any deposition. 4. Any document needed to lay the foundation for any document. Plaintiffs reserve the right to supplement this list prior to trial. Plaintiffs do not stipulate to or introduce every exhibit listed herein. DATED: October 11, 2021 /s/Laura Browne _______ Original Signature on File in Attorney’s Office Laura Browne, Attorney for Plaintiffs CERTIFICATE OF SERVICE I certify that on October 11, 2021, this PLAINTIFFS’ PRELIMINARY EXHIBIT LIST was served on all parties via CCEF electronic filing to the following: Andrew W. Callahan, Esq. Julie M. Yates, Esq. WICK & TRAUTWEIN, LLC P.O. Box 2166 Fort Collins, CO 80522 Attorney for Defendant Adam Stephens, Esq. FORT COLLINS CITY ATTORNEY’S OFFICE P.O. Box 580 Fort Collins, CO 80522 Attorney for Defendant /s/ Kassandra Burival Original Signature on File in Attorney’s Office Kassandra Burival, Paralegal