Civil Litigation
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Motion to exclude firearms in deposition
Motion to modify scheduling order to exclude individuals from carrying firearms in deposition
Defendants Motion in Limine
Defendants Motion in Limine in excessive force case to exclude unrelated claims against defendant’s
Stipulated Motion for Protective Orders
A partial stipulated motion for protective orders in an excessive force case
Motion for leave to file excessive pages
Motion for leave to file excessive pages to a response to a motion to dismiss
Complaint Excessive Force
A complaint filed against Denver Police for excessive force
Answer to Excessive Force Complaint
An answer filed in a excessive force case against City of Denver
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
PLAINTIFF’S MOTION FOR ATTORNEYS’ FEES PURSUANT TO 42 U.S.C. § 1988
PLAINTIFF’S MOTION FOR ATTORNEYS’ FEES PURSUANT TO 42 U.S.C. § 1988
OPPOSED MOTION FOR STAY OF EXECUTION OF FINAL JUDGMENT AND WAIVER OF APPEAL BOND
OPPOSED MOTION FOR STAY OF EXECUTION OF FINAL JUDGMENT AND WAIVER OF APPEAL BOND
PLAINTIFF’S MOTION TO EXCLUDE EVIDENCE OF ALLEGED CODE VIOLATIONS DISCOVERED AFTER AUGUST 2013
PLAINTIFF’S MOTION TO EXCLUDE EVIDENCE OF ALLEGED CODE VIOLATIONS DISCOVERED AFTER AUGUST 2013
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT AND MOTION TO DISMISS
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT AND MOTION TO DISMISS
UNOPPOSED MOTION FOR LEAVE TO TAKE THE DEPOSITION OF AFTER DISCOVERY CUT-OFF
UNOPPOSED MOTION FOR LEAVE TO TAKE THE DEPOSITION OF AFTER DISCOVERY CUT-OFF
DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT AND MOTION TO DISMISS
DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT AND MOTION TO DISMISS
Administrative Pre-hearing statment
A Colorado State Personnel appeal, where my client was wrongfully terminated. A pre-hearing statement is filed prior to the hearing