Civil Litigation
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Defendants’ Trial Brief
A small sample brief to a defense against the fair labor standard act and Colorado minimum wage act.
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’.
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.
Motion to Dismiss Breach of Insurance Complaint
Motion and Brief in Support of Motion to Dismiss for failure to state a claim against insurance
Plaintiff’s Response to Defendants’ Motion to Dismiss
PLAINTIFF’ S RESPONSE TO DEFENDANTS’ MOTION TO DISMISS based on Qualified Immunity
Motion to Stay Discovery
Motion to Stay Discovery until Motion to dismiss is addressed