Civil Litigation
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Procedural Objection to Motion for Summary Judgement – Dram Shop
PROCEDURAL OBJECTION TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT DRAM SHOP
Federal Lawsuit for Discrimination
Complaint in Colorado Federal District Court for Civil Rights Violations and Retaliation. Title VII complaint based on Sexual Harassment.
Consent to Implement Direct Assignment Civil Cases to Full-Time Magistrate
CONSENT FORM PURSUANT TO PILOT PROGRAM TO IMPLEMENT THE DIRECT ASSIGNMENT OF CIVIL CASES TO FULL TIME MAGISTRATE JUDGES
Answer to Mechanics Lien with Affirmative Defenses
Answer that was filed in a multi million dollar lawsuit where the claims where breach of contract and Equitable relief and Lien Foreclosure
Complaint: Class Action for Civil Rights Violations Under Title VII Discrimination
A 34 page complaint filed against a City for a pattern of practice of discrimination against Police Officer based on race. Failure to promote, hire and disciplined employees in violation of Title VII
Plaintiff Response to Defendants City Motion for Summary Judgement
Response to motion for summary judgement in employment discrimination case. Client is a police officer that was passed over for a promotion.
Amended Complaint & Jury Demand
A complaint filed In Colorado Federal District Court claiming discrimination based on race and for retaliation
Entry of Apprearance & Motion for Leave of the Court to File Answer & Cross-claim
Represented a name defendant
Plaintiff Objection to Motion in Limine – Insurance Law
Plaintiff response to motion to include insurance name in voir dire
Premise liability and assault Complaint
Complaint against bar owner for failure to provide a safe environment for patron as well as complaint against unknown person who assaulted client
Settlement Demand for an Auto Accident Case
A simple settlement letter to insurance company for auto accident. I also attached the settlement calculation breakdown sheet. A demand letter is one of the most important steps in a car insurance claim after an accident. In the demand letter, the injured claimant sets out the facts and circumstances of the accident and resulting medical treatment, and sets the stage for injury settlement negotiations to begin in earnest.