Civil Litigation
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DEFENDANTS’ RESPONSE IN OPPOSITION TO PLAINTIFFS MOTION FOR ATTORNEY FEES AND COSTS AND REQUEST FOR HEARING
A sample response to request for attorney fees including a request for a hearing on the attorney fees matter.
Defendants Motion in Limine Related to Limitations Period
A sample motion by defendant limiting testimony for claims made outside the statue of limitations.
Defendants Jury Instructions
Sample jury instructions with citations for a fair labor standard act.
Complaint – Second Amended
A sample amended complaint adding a third claim for relief under the federal fair labor standard act.
Answer to First Amended Complaint
Sample answer and defense to a claim for unfair wages.
Answer
A sample answer defending a claim against the federal wage statues.
Amended Trial Management Order
A sample proposed trial management order which states plaintiff’s claim for relief, defendant’s claim and defenses, as well as stimulated facts and a list of witness’.
Letter to Life Insurance Company for Claim
A sample letter to send to life insurance company by a beneficiary of the life insurance policy. I recommend sending this out shortly after receiving the death certificate. Make sure to include the death certificate, as well.
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.
Guide To Colorado Unemployment Benefits
A Employee and Employer Guide to Colorado Unemployment benefits, What to expect, how to apply for unemployment benefits, Do you qualify? If you are denied, How to appeal.
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 to Dismiss Breach of Insurance Complaint
Motion and Brief in Support of Motion to Dismiss for failure to state a claim against insurance