Civil Litigation
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Plaintiff’s Brief in Support of Motion for Temporary Injunction and Expedited Discovery
Plaintiff’s Brief in support of motion for temporary injunction and expedited discovery, from the US District Court for the District of Minnesota. Companion Objection to same, as well as the original complaint, available on Lawyers Help Lawyers as well.
Federal Civil Complaint for Default on Promissory Note
Federal Civil Court Complaint for default on a promissory note. Diversity case out of the US District Court for the Eastern District of Michigan.
Federal Civil Complaint for Copyright Infringement
Federal Civil Complaint for violation of copyright.
As a general matter, copyright infringement occurs when a copyrighted work is reproduced, distributed, performed, publicly displayed, or made into a derivative work without the permission of the copyright owner.
Copyright infringement can be a felony or a misdemeanor. A felony charge must involve an infringement of the copyright owner’s reproduction or distribution rights. A felony conviction carries a maximum sentence of five years in prison and a maximum fine of $250,000.
Copyright infringement is using someone else’s work without getting that person’s permission. … The owner of a copyright gets to decide who can legally make copies of that work. It is illegal to copy large sections of someone else’s copyrighted work without permission, even if you give the original author credit.
The legal penalties for copyright infringement are: Infringer pays the actual dollar amount of damages and profits. The law provides a range from $200 to $150,000 for each work infringed. Infringer pays for all attorneys fees and court costs.
US District Court for the Eastern District of Michigan
Plaintiff’s Memorandum in Support of Motion for Approval of Plan for Class Notice
Plaintiff’s Brief in support of class action notice to class members following class certification. US District Court for the District of Colorado.
Civil Complaint for Damages, Declaratory Relief, Extraordinary Writs, and Preliminary Injunction
Federal Civil Rights Complaint (42 USC 1983), including requests for damages, injunction, extraordinary writs, and declaratory relief out of the US District Court for the Eastern District of Michigan.
Declaratory relief refers to a judgment of a court which determines the rights of parties without ordering anything be done or awarding damages. By seeking a declaratory judgment, the party making the request is seeking for an official declaration of the status of a matter in controversy.
The declaratory judgment is generally considered a statutory remedy and not an equitable remedy in the United States, and is thus not subject to equitable requirements, though there are analogies that can be found in the remedies granted by courts of equity.
Declaratory relief refers to a judgment of a court which determines the rights of parties without ordering anything be done or awarding damages. By seeking a declaratory judgment, the party making the request is seeking for an official declaration of the status of a matter in controversy.
Defendant’s Memorandum in Support of its Motion to Dismiss
Defense Brief supporting motion to dismiss a misappropriation of trade secrets and breach of contract case under diversity jurisdiction. US District Court for the District of Minnesota.
Federal Civil Complaint under 42 USC 1983 (Excessive Force)
Civil Complaint pursuant to 42 USC 1983 for police use of excessive force. US District Court for the Eastern District of Michigan.
Federal Civil Complaint under ERISA
Federal ciil complaint brought under ERISA against Veteran’s Affairs. US District Court for the Eastern District of Michigan.
Defendant’s Memorandum in Opposition to Plaintiff’s Motion for Temporary Injunction and Expedited Discovery
Defendant’s opposition brief in opposition to motion for temporary injunction and expedited discovery. Includes analysis of competing state laws. US District Court for the District of Minnesota.
Petition for Recusal Pursuant to 28 USC Sec. 144 and 18 U.S.C. Sec. 455
Defendant’s Petition for judicial recusal based on bias.
Plaintiff’s Response and Objections to Notice to Take the Videotaped Deposition of and Subpoena Duces Tecum
PLAINTIFF’S RESPONSE AND OBJECTIONS TO NOTICE TO TAKE THE VIDEOTAPED DEPOSITION aND SUBPOENA DUCES TECUM
Plaintiff’s Memorandum Brief in Opposition to Defendant, M.D.’S C.R.M. 7 Petition for Review of Magistrate’s Order
PLAINTIFF’S MEMORANDUM BRIEF IN OPPOSITION TO DEFENDANT , M.D.’S C.R.M. 7 PETITION FOR REVIEW OF MAGISTRATE’S ORDER
Defendant C.R.M. 7 Petition for Review of Magistrate’s Order
DEFENDANT C.R.M. 7 PETITION FOR REVIEW OF MAGISTRATE’S ORDER
Defendant’s Initial Rule 26 Disclosures – Personal Injury
A party must make its initial disclosures based on the information then reasonably available to it. In addition to the disclosures required by Rule 26(a)(1), a party must disclose to the other parties the identity of any witness it may use at trial to present evidence under Federal Rule of Evidence 702, 703, or 705. Appendix A to these disclosures identifies those individuals who may have discoverable information relevant to disputed facts alleged with particularity in the pleadings.
Motion to Preclude Client from Introducing Evidence or Testimony – Plaintiff was not Informed of Her Right to Undergo Testing
PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION IN LIMINE TO PRECLUDE PLAINTIFF FROM ARGUING, OR INTRODUCING EVIDENCE OR TESTIMONY, THAT PLAINTIFF WAS NOT INFORMED OF HER RIGHT ON AUGUST 1, 2012, TO UNDERGO TESTING TO DEFINITIVELY RULE OUT THE POSSIBILITY OF INFECTION