Employment and Labor
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Plaintiff’s Motion for Liquidated Damages and Statutory Penalties
A motion for liquidated damages and penalties after a jury finds a defendant guilty of violating the fair standard act.
Plaintiffs Unopposed Motion For Enlargement Of Time To Submit Expert Rebuttal Disclosures, Pursuant To C.R.C.P. Rule 6
A motion to request an extension of time to submit expert’s reports.
PLAINTIFFS’ UNOPPOSED MOTION FOR LEAVE TO AMEND COMPLAINT TO JOIN ADDITIONAL PARTY
A sample motion to leave to add an additional party.
Employment Contract for a Bilingual Receptionist & Secretary
A employment contract for a bilingual receptionist or secretary. The contract include employer providing phone for remote receptionist to answer. Termination and return of property are also included in the terms of the contract. State can easily be changed to use in any state or jurisdiction
Defendants’ Trial Brief
A small sample brief to a defense against the fair labor standard act and Colorado minimum wage act.
Discrimination complaint
Title VII complaint with Wrongful Discharge in Violation of Public Policy as set forth in the Colorado Anti-Discrimination Act
Federal Civil Complaint under ERISA
Federal ciil complaint brought under ERISA against Veteran’s Affairs. US District Court for the Eastern District of Michigan.
Complaint for Injunctive Relief & Damages Discrimination
RETALIATORY DISCHARGE IN VIOLATION OF THE FAMILY AND MEDICAL LEAVE ACT, WRONGFUL TERMINATION BASED ON DISABILITY DISCRIMINATION, FAILURE TO PROVIDE REASONABLE ACCOMMODATION
Complaint for Fair Labor Standard Act – Ohio
1. the Fair Labor Standards Act (“FLSA”), 29 U.S.C. §201, et seq., the Ohio Minimum Fair Wage Standards Act, O.R.C. Chapter 4111 (“the Ohio Wage Act”), the Ohio Prompt Pay Act, O.R.C. § 4113.15 (“OPPA”), and 28 U.S.C. §1331.
Complaint – Second Amended
A sample amended complaint adding a third claim for relief under the federal fair labor standard act.
defendan brief in opposition to injunctive relief
DEFENDANT’S MEMORANDUM IN OPPOSITION TO PLAINTIFF’S MOTION FOR A TEMPORARY INJUNCTION AND EXPEDITED
DISCOVERY
