Civil Litigation
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Age and Disability Complaint (Employment Law)
Complaint filed in Federal district court for damages for Age Discrimination and ADEA
Response to Motion to Vacate a Default Judgment & Motion to Strike Answer
Great response to a Defendant who failed to file an answer and then after judge ordered default, defendant filed a motion to vacate the default and a motion to leave to file an answer.
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
Defendant Order to Show Cause – Appeals Court
An Appeal to Supreme Court Petitioner, PETITIONER’S NAME, asks this Court to determine an important and unresolved question concerning ex parte meetings with a plaintiff’s treating physicians pursuant to
Complaint for Violation Fair Debt Collection Act
Complaint filed under the Fair Debt Collection Act, VIOLATIONS OF THE GEORGIA FAIR BUSINESS PRACTICES ACT
O.G.C.A. § 10-1-393(a) and VIOLATIONS OF THE TELEPHONE CONSUMER PROTECTION ACT 47 U.S.C. §§ 227(b)(1)(A)(iii)
Complaint and jury demand for FLSA
A complaint under the fair standard act for overtime payment
Complaint For ERISA
Filed this complaint for ERISA benefits from a denial of long term benefits
American Disabilities Act Complaint – Georgia
Compliant filed in Georgia Northern Federal District Court for ADA and lack of access to business
Complaint to Determine Medicare Lien
Complaint filed to determine proper medicare lien – Missouri
Motion to Dismiss FED Case-Landlord and Tenant
Motion to Dismiss a FED case for lack of proper service and improper pleading. Ultimately, it worked, but the court still required a hearing.
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.
Motion For Damages – Post Lawsuit
Motion for damages after winning the lawsuit
Complaint for Discrimination
Compliant under Title VII gender discrimination and SECOND CAUSE OF ACTION FOR VIOLATIONS OF THE NEW YORK STATE HUMAN RIGHTS LAW FOR GENDER DISCRIMINATION AND SEXUAL ORIENTATION DISCRIMINATION
Complaint to Affirm Arbritation
Petition to confirm arbitration award