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Plaintiff’s Response to Defendant’s Motion for Summary Judgment
Plaintiff’s Response to Defendant’s Motion for Summary Judgment
Memorandum of Law re Defendant’s Request to Take Judicial Notice of Weather Data Published by the National Oceanic and Atmospheric Administration
Memorandum of Law re Defendant’s Request to Take Judicial Notice of Weather Data Published by the National Oceanic and Atmospheric Administration
Defendant’s Objections to Plaintiff’s Subpoena to Produce Documents to Memorial Hospital
Defendant’s Objections to Plaintiff’s Subpoena to Produce Documents to Memorial Hospital
Defendant’s Objections to Plaintiff’s Subpoena to Produce Documents to Front Range Orthopaedics
Defendant’s Objections to Plaintiff’s Subpoena to Produce Documents to Front Range Orthopaedics
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.
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.
Hearsay Medical Records, Motion in Limine Precluding
MIL to Preclude Hearsay testimony reading of medical records
Federal Court Civil Complaint with Request for Injunctive Relief
Federal Civil Complaint based on diversity of citizenship, and including claims for misappropriation of trade secrets and breach of contract; includes request for injunctive relief. US District Court for the District of Minnesota.
Affidavit of Attorney’s Fees & Costs on Motion to Compel
AFFIDAVIT OF ATTORNEY’S FEES AND COSTS on motion to compel
Complaint for Civil Theft
Complaint against company for civil theft and fraud
Confidential Settlement Statement – Construction Mediation
A confidential settlement statement for construction case. Construction projects often produce disputes. Mediation can help resolve such disputes, quickly, confidentially, and efficiently.
Forms of mediation vary greatly, from facilitative (with the mediator encouraging parties to consider the benefits of settlement, and creative alternatives for dispute resolution), to evaluative (with the mediator providing a non-binding assessment of the strengths and weaknesses of positions, to help parties rationally evaluate the benefits of settlement), and a variety of other forms. Mediators, moreover, vary, from subject matter experts (including non-lawyer professionals) to experts in dispute resolution (including ex-judges and highly experienced counsel).
Get a process, and a mediator, that is right for your dispute. Even if the process is not specified in a contract, or if mediation is directed by a court, you still have the ability to shape the process (on agreement with the adversary). Since you share an interest in ensuring that the process succeeds, early discussion with adversaries about the needs of the dispute should be a high priority.
Motion for Extension of Time to File Answer or Other Respond to Complaint
A motion for extension of time to file and answer or respond to complaint in a civil action, with a proposed order
A Letter Response to an EEOC Complaint
Represented a company being charged with discrimination against a woman. Our letter was written in response to the EEOC Charge
Complaint for Injuries as a Result of a Ski Accident
A complaint filed against an individual who resides outside the country for injuries he caused in a ski collision