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   State Courts - Colorado - October 15, 2009
  
Sawyer v. Kindred Nursing Ctrs. West, LLC, Court of Appeals Nos. 08CA0811 & 08CA1514, COURT OF APPEALS OF COLORADO, DIVISION FIVE, October 15, 2009, Decided
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Overview: Court erred in dismissing mother's negligence action against nursing home after she died because Colo. R. Civ. P. 25(a)(1) was applicable to claim; because mother's daughters were not personally served with suggestion of death, as required for non-parties, 90-day limit to substitute parties was not triggered and court improperly dismissed the suit.

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