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Chad Lieberman

Since my post on the collateral source rule, I have received (and raised) questions regarding discoverability of collateral source information. On speaking with colleagues, particularly on the listserv, this issue is gaining steam. Most plaintiff’s attorneys will not voluntarily disclose the amount of the collateral source payments (i.e. Medicare and Medicaid). The courts are being tasked […]

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You can no longer leave the following voicemail:  “Hi. I see you were already served with the records subpoena. If you want to avoid attending the records deposition, please forward copies of the requested documents to my attention.” I repeat: You can no longer leave that voicemail. The Colorado Supreme Court recently articulated the procedural […]

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In Colorado, collateral source matters are governed by both common law and statute.  The collateral source rule consists of two components: (1) a post-verdict set-off rule; and, (2) a pre-verdict evidentiary rule. Historically under the common law collateral source rule, any third-party payments or benefits received by a plaintiff accrued solely to the plaintiff’s benefit […]

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The video-conference deposition itself sounds like a great idea.  After all, we were supposed to have flying cars and robot maids by now.  However, the reality of video-conference deposition reveals many, many challenges. The first and most obvious challenge is the technology. Through trial and error, I would always suggest using a court reporter’s office, […]

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Few things make me happier than a double monitor. If I had my druthers, I would set my office up to mirror the docking stations in “The Matrix.” I would have 15 screens with scrolling green letters and numbers … The legend of the quad-monitor is quietly whispered throughout the halls of Micro Center and […]

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I recently found an area of law that I never knew existed: local counsel.  Before moving to Denver, everything for me was local.  I grew up in Chicago, went to school in Chicago, and worked in Chicago.  My blood pumps celery salt, mustard, and sport peppers.  But then something changed.  I met a girl, got […]

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