Brief on Motion for Summary Judgment on Breach of Contract/excessive lien
Great brief on a breach of construction contract claim and lien, where my client was claiming the lien filed was excessive
Product Liability Lawsuit – Federal Court Civil Complaint and Jury Demand
Federal Court Civil Complaint, including claims for Strict Liability, Product Liability-Failure to Warn, Negligence, Breach of Warranty- Express and Implied, Fraud, Fraudulent Concealment, and Negligent Representation.
Product liability is the area of law in which manufacturers, distributors, suppliers, retailers, and others who make products available to the public are held responsible for the injuries those products cause.
Product Defects: Responsible Parties
For product liability to arise, at some point the product must have been sold in the marketplace. Historically, a contractual relationship, known as “privity of contract,” had to exist between the person injured by a product and the supplier of the product in order for the injured person to recover. In most states today, however, that requirement no longer exists, and the injured person does not have to be the purchaser of the product in order to recover. Any person who foreseeably could have been injured by a defective product can recover for his or her injuries, as long as the product was sold to someone.
Liability for a product defect could rest with any party in the product’s chain of distribution, such as:
-The product manufacturer;
-A manufacturer of component parts;
-A party that assembles or installs the product;
-The wholesaler; and
-The retail store that sold the product to the consumer.
Federal Civil Complaint for Default on Promissory Note
Federal Civil Court Complaint for default on a promissory note. Diversity case out of the US District Court for the Eastern District of Michigan.
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 & Jury Demand for Embezzlement and Fraud
complaint and jury demand for embezzlement and fraud
Plaintiff’s Brief in Support of Motion for Temporary Injunction and Expedited Discovery
Plaintiff’s Brief in support of motion for temporary injunction and expedited discovery, from the US District Court for the District of Minnesota. Companion Objection to same, as well as the original complaint, available on Lawyers Help Lawyers as well.
Motion for Clerk to Enter Default
we filed a lawsuit for breach of contract and civil theft. The Defendants failed to answer the complaint. first step is to file a Motion for the Clerk to enter Default once the clerk enters default next would be to file a Motion for Default judgment
Demand Letter for Money Owed
A demand letter is a written request that individuals send to demand a payment to reach a settlement without going to court to dispute it. This letter will state the purpose for writing the letter, request payment by a certain date, and threaten legal action if there is no response. Simply fill in the pre-populated terms and send it to the debtor or have your attorney send it.
Amended answer to PI lawsuit
Amended answer for a auto accident case, whereas the manufacturer was sued for defective vehicle. Sample answers including not doing business in state of Colorado, other affirmative defenses.
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
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.
Breach of Contract/ Breach of Warranty and Implied Warranty
I used this complaint in a successful lawsuit against a contractor that did not perform his duty as hired. Work was not done in a professional manner, filed this complaint and won a jury trial.