Defendant’s Memorandum in Opposition to Plaintiff’s Motion for Temporary Injunction and Expedited Discovery
Defendant’s opposition brief in opposition to motion for temporary injunction and expedited discovery. Includes analysis of competing state laws. US District Court for the District of Minnesota.
Complaint & Jury Demand for Embezzlement and Fraud
complaint and jury demand for embezzlement and fraud
Stipulation to hold issue in abeyance
Stipulation to hold issue and continue hearing
Motion in limine that defendant did not recive ticket
In a auto accident case plaintiff filed motion to limit the defense from mentioning that defendant did not get a ticket
Complaint for Violation Fair Debt Collection Act
Complaint filed under the Fair Debt Collection Act, VIOLATIONS OF THE GEORGIA FAIR BUSINESS PRACTICES ACT
O.G.C.A. § 10-1-393(a) and VIOLATIONS OF THE TELEPHONE CONSUMER PROTECTION ACT 47 U.S.C. §§ 227(b)(1)(A)(iii)
Motion for Attorney’s Fees Pursuant-Landlord and Tenant
A Motion for an award of attorney’s fees in a civil FED case. Filed under 13-17-101 CRS, seeking the award for a substantially frivolous, groundless, and/or vexatious action and/or pleading. Fact specific, but a good starting point in any request for fees. It was ultimately denied as the defendant “was not aware of the possibility of an award of attorney’s fees” under 13-17-102(6), despite having had several discussions about exactly that on the record.
Complaint for Excessive Force
Complaint Excessive force for an off duty police officer working for a bar
Complaint for Fair Debt Act
A lawsuit Filed for Violation For Federal Fair Debt Act
Jury instructions for Antitrust, Sherman Act, Civil Conspiracy Federal Lawsuit
Jury instructions with cites for Antitrust, Sherman Act, Civil Conspiracy Federal Lawsuit, Plaintiff won a 1.3 million dollar judgment
Complaint (lawsuit) for Sherman Act/ Antitrust
A Civil Federal lawsuit complaint filed for antitrust violations, violation of the Sherman Act.
Response to motion for Summary Judgment on Title VII Discrimination
A Plaintiff response to motion for summary judgment in a Title VII case against the City Police Department
Medical Malpractice VOIR DIRE QUESTIONS
Voire Dire questions used in medical malpractice case.
Motion for Independent Med Exam Pursuant to C.R.C.P. 35(a) + Ruling
A response to a motion for independent medical examine in a personal injury cases. After any kind of accident, the first medical treatment is often performed by a doctor of the injured person’s own choosing (maybe even their own physician). Naturally, when a personal injury claim is filed over the accident, the defendant (or their insurance company) will want a second opinion and may request an IME. In general, an IME is performed by a licensed doctor of medicine (MD) or doctor of osteopathic medicine (OD), usually one with medical knowledge or training in the specific area relating to the case, and with experience in the area of IMEs.
Complaint and Jury Demand (personal injury)
Complaint and Jury Demand (personal injury)