Civil Litigation
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Plaintiffs Response to Defendants Motion to Strike Plaintiffs Motion to Compel
Plaintiffs Response to Defendants Motion to Strike Plaintiffs Motion to Compel
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Complaint for Fair Labor Standard Act
Complaint under the fair labor standard act for failure to pay overtime and retaliation
Response Brief to Motion for Summary Judgment
Insurance interpleader case where there was a dispute as to who gets a life insurance policy. I represented the name beneficiary and the other party was the descendants two daughters. The daughters claimed they were entitled to insurance proceeds because he was required to pay child support. This my response to their motion for summary judgment.
Plaintiff’s Motion to Strike Testimony
Plaintiff’s Motion to Strike Testimony
Motion to Enforce Settlement Agreement-Civil
Motion to Enforce Settlement Agreement in civil money case.
Workers Comp Motion for Leave to File Amended Response Brief
MOTION FOR LEAVE TO FILE AMENDED RESPONSE BRIEF
Motion for Attorney’s Fees Pursuant-Landlord and Tenant
A Motion for an award of attorney’s fees in a civil FED case. Filed under 13-17-101 CRS, seeking the award for a substantially frivolous, groundless, and/or vexatious action and/or pleading. Fact specific, but a good starting point in any request for fees. It was ultimately denied as the defendant “was not aware of the possibility of an award of attorney’s fees” under 13-17-102(6), despite having had several discussions about exactly that on the record.
Plaintiff’s Objection to Computer Expert & Request for Shrek Hearing
PLAINTIFF’S OBJECTION TO DEFENSE COMPUTER “EXPERT” REQUEST FOR SHREK HEARING
Procedural Objection to Defendant’s Motion – Missed Deadline
PROCEDURAL OBJECTION TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT MISSED DEADLINE
Defendant’s Response to Plaintiff’s Post-Trial Motion to Exceed the $1,000,000.00 Cap
DEFENDANT’S RESPONSE TO PLAINTIFF’S POST-TRIAL MOTION TO EXCEED THE $1,000,000.00 CAP CONTAINED IN C.R.S. § 13-64-302(1)(b)
Plaintiff’s Objection and Request for Hearing on Defendant’s Motion for Fees and Bill of Cost
PLAINTIFFS’ OBJECTION AND REQUEST FOR HEARING ON DEFENDANTS’ MOTION FOR FEES AND BILL OF COSTS
Defendant’s Objections to Non-Stipulated Jury Instructions
DEFENDANT’S OBJECTIONS TO PLAINTIFF’S NON-STIPULATED AND COMPETING JURY INSTRUCTIONS AND COMPETING VERDICT FORM for Discrimination
Defendant Counter-Designations and Objections Regarding Deposition Testimony
DEFENDANT COUNTER-DESIGNATIONS AND OBJECTIONS REGARDING DEPOSITION TESTIMONY OF —