Civil Litigation
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Model Telecommuting Letter Agreement
This is model telecommuting agreement between an employer and employee provides key terms of the arrangement.
Confidentiality Agreement for Employees/Consultants of Art Advisory Services
This Confidentiality Agreement is for employees or consultants who provide art advisory and consultation services. It contains provisions that are specific to the fine art world and has tailored provisions for “family” like employers who may have unique confidentiality requirements relative to a large organization.
Reply in Support of Motion for Pro Hac Vice Admission
Plaintiff’s reply in support of defendant’s motion for pro hac vice admission.
Response to Plaintiffs’ Motion to Exclude Defendants’ Experts
Plaintiff’s motion to limit the testimony of four of the defendants’ experts.
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.
Plaintiff’s Response to Defendants’ Motion to Dismiss
PLAINTIFF’ S RESPONSE TO DEFENDANTS’ MOTION TO DISMISS based on Qualified Immunity
PLAINTIFF’S RESPONSE AND OBJECTION TO DEFENDANTS’ MOTION FOR SUMMARYJUDGMENT AND MOTION TO DISMISS
PLAINTIFF’S RESPONSE AND OBJECTION TO DEFENDANTS’ MOTION FOR SUMMARYJUDGMENT AND MOTION TO DISMISS
Defendants-Counterclaimant’s Response to Plaintiff’s Motion for Summary Judgement
DEFENDANTS-COUNTERCLAIMANTS’
RESPONSE TO PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT
Defendants Ground’s Response to Plaintiff’s Verified Motion for Appointment of Receiver
DEFENDANT GROUND’S RESPONSE TO PLAINTIFF’S VERIFIED MOTION FOR APPOINTMENT OF RECEIVER
Verified Response: Verified Motion to Receiver
VERIFIED RESPONSE: VERIFIED MOTION TO RECEIVER
RESPONSE TO MOTION TO CONFIRM ARBITRATION AWARD
RESPONSE TO MOTION TO CONFIRM ARBITRATION AWARD
RESPONSE TO MOTION TO MODIFY CHILD SUPPORT
RESPONSE TO MOTION TO MODIFY CHILD SUPPORT
PETITIONER’S RESPONSE TO MOTION TO MODIFY TEMPORARY ORDERS
PETITIONER’S RESPONSE TO MOTION TO MODIFY TEMPORARY ORDERS
Defendant Response in Opposition to Plaintiff’s Motion in Limine to Preclude Evidence of “Small Print”
DEFENDANT RESPONSE IN OPPOSITION TO PLAINTIFF’S MOTION IN LIMINE TO PRECLUDE EVIDENCE OF “SMALL PRINT” DISCLAIMERS OF WARRANTIES PURSUANT TO THE UCC
Response to Motion to Exclude Testimony of Non-Retained Experts
RESPONSE IN OPPOSITION TO DEFENDANT/COUNTERCLAIM PLAINTIFF MOTION TO EXCLUDE TESTIMONY OF NON-RETAINED EXPERTS