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Motion in Limine: Case No. 02CW38
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Motion in Limine: Case No. 02CW38
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Last modified
1/26/2010 4:41:46 PM
Creation date
7/30/2009 1:08:44 PM
Metadata
Fields
Template:
Water Supply Protection
File Number
8230.2B2
Description
Discovery
State
CO
Basin
Colorado Mainstem
Water Division
4
Date
8/29/2003
Author
Ken Salazar, Susan J. Schneider, Lori J. Coulter
Title
Motion in Limine: Case No. 02CW38
Water Supply Pro - Doc Type
Court Documents
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Co., 661 P.2d 684, 694 (Colo.App. 1982). The trial court has broad discretion to <br />determine the sanctions to be imposed on a pariy for failure to disclose the substance of <br />testimony intended to be elicited from a witness. C.R.C.P. 16(d)(3); Wood v. Rowland, <br />592 P.2d 1332 (Colo. App. 1978). This is especially true in view of the continuing duty <br />to disclose and supplement in a reasonable manner the substance of an expert witness' <br />testimony. C.R.C.P. 26(e)(1); Dolan v. Mitchell, 502 P.2d 72 (1972). CRWCD's <br />complete failure to meet the requirements of C.R.C.P. 26(a)(2) is grounds for exclusion <br />of the testimony of its expert. Further, since there are other experts in this case who will <br />present testimony on the same subject matter, Mr. Kuhn's opinions would be merely <br />cumulative and not necessary to the resolution of the case (the CRVJCD and the CWCB <br />are co-objectors in this case). <br />This Court Should Limit Ezpert Testimony to Scientific Facts and Not Allow <br />Legal Conclusions <br />Second, the State also requests the exclusion of the expert testimony of Eric Kuhn <br />because his opinions ultimately concern the legal definitions of "maximum utilization" <br />and "compact impairment." Similarly, the Sta.te also requests the exclusion of the <br />testimony of Jim Lochhead, to the extent his testimony will concern these same legal <br />definitions. <br />The legal definitions of what constitutes "maximum utilization" and "compact <br />impairment" under section 37-92-102(6)(a)(I) &(V), C.R.S. (2002) are undecided legal <br />terms that this Court must rule upon in this case of first impression. "Although opinion <br />testimony is not objectionable merely because it embraces an ultimate issue of fact, an <br />expert may not usurp the function of the court by expressing an opinion of the applicable <br />law or legal standards." Quintana v. City of Westminster, 8 P3d 527 (Colo. App. 2000); <br />People v. Lesslie, 939 P.2d 443 (Colo.App.1996); Grogan v. Taylor, 877 P.2d 1374, 1384 <br />(Colo. App. 1993)(rev'd on other grounds). <br />A witness cannot be allowed to give an opinion on a question of law.... In order <br />to justify having courts resolve disputes between litigants, it must be posited as an <br />a priori assumption that there is one, but only one, legal answer for every <br />cognizable dispute. There being only one applicable legal rule for each dispute or <br />issue, it requires only one spokesman of the law, who of course is the judge.... To <br />allow anyone other than the judge to state the law would violate the basic concept. <br />Reducing the proposition to a more practical level, it would be a waste of time if <br />witnesses or counsel should duplicate the judge's statement of the law, and it <br />would intolerably confound the jury to have it stated differently. <br />Stoebuck, Opinions on Ultimate Facts: Status, Trends, and a Note of Caution, 41 <br />Den.L.Cent.J. 226, 237 (1964) (footnote omitted). <br />A trial court must effectively control the scope of examination to insure that an <br />expert witness does not testify concerning ultimate issues of law before the court. <br />Boettcher DTC Bldg. Joint Venture v. Falcon Ventures, 762 P.2d 788 (Colo. App. 1988).
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