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The Colorado Supreme Court ruled in the case of In re: Averyt v. Wal-Mart Stores, Inc. that a party is not required to automatically disclose public documents that are equally accessible to all parties under C.R.C.P. 26(a)(1). The court found sufficient evidence supporting the jury's damages verdict in favor of Holly Averyt, who suffered injuries from a slip at a Wal-Mart store, and reversed the trial court's order granting Wal-Mart a new trial based on alleged discovery violations.

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