Motion Pattern Analytics

Fed. R. Civ. P. 26(b)(1)

Fed. R. Civ. P. 45(d)(2)(B)(i)

Netlist, Inc. v. Intel Corp., 2023 WL 6345979

611 Carpenter LLC v. Atlantic Casualty Ins. Co., 2024 1977160

DEFENDANT CITY OF HUTTO'S RULE 59 MOTION → CERTIFICATE OF CONFERENCE → STATUS OF THE CASE → THE GROUNDS FOR THIS MOTION → FACTUAL BACKGROUND → A. THE DAMAGE AWARD → B. ODIS JONES DAMAGE EVIDENCE → ARGUMENT AND AUTHORITIES

I. → II. → III. → WHEREFORE:

the matters detailed in exhibit a are irrelevant to any provable or controlling fact issue in dispute in this breach of contract claim.

the matters in exhibit a do not have a tendency to make the existence of any fact of consequence to the determination of the action more probable or less probable.

permitting interrogation of witnesses or offers of evidence concerning these matters would result in irreparable prejudice and harm to defendant's case.

the probative value of the matters set forth in exhibit a is substantially outweighed by the danger of unfair prejudice, confusion of the issues, or misleading the jury.

plaintiff violated a clear agreement regarding the scope of review of cynthia davis's phone data.

Cain v. Hearst Corp., 878 S.W.2d 577 (Tex.1994)

Blanche v. First Nationwide Mortg. Corp., 74 S.W.3d 444 (Tex.App.-Dallas 2002)

the jury's damage awards of $12.5 million are excessive under federal case law and vastly exceed maximum recovery sanctioned in similar cases, indicating the verdict was the result of passion or preju

the jury's 'nuclear verdict' was fueled by passion or prejudice, as evidenced by the lack of specific damage evidence presented by plaintiff and the jury's questions seeking relief outside the confine

the jury verdict constitutes a prohibited double recovery under texas law because the allegations of breach and damages for the section 1981 and breach of contract claims are identical, arising from t

plaintiff lacks standing for the section 1981 claim because the alleged discriminatory acts, specifically the city's letters, do not constitute a violation of section 1981 as they did not interfere wi

there is no legally sufficient evidentiary basis to support the jury's finding that the defendant breached the separation agreement or that the city council's actions were racially motivated, as requi

Fed. R. Civ. P. 59(a)

Honestech, Inc. v. Sonic Solutions, 725 F. Supp. 2d 573, 577 n.1 (W.D. Tex. 2010)

Gov't Fin. Servs. One Ltd. P'ship v. Peyton Place, Inc., 62 F.3d 767, 774 (5th Cir. 1995)

Whitehead, 163 F.3d at 275 (5th Cir. 1998)