Civil Litigation
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Settlement Demand for an Auto Accident Case
A simple settlement letter to insurance company for auto accident. I also attached the settlement calculation breakdown sheet. A demand letter is one of the most important steps in a car insurance claim after an accident. In the demand letter, the injured claimant sets out the facts and circumstances of the accident and resulting medical treatment, and sets the stage for injury settlement negotiations to begin in earnest.
Motion to quash subpoena deuces tecum
Filed a motion to quah a subpoena for the release of state health records regarding marijuana use
Motion to Dismiss Lawsuit
A lawsuit was filed by against an attorney by a former opposing party. We responded with a motion to dismiss that was granted and later confirmed by court of appeals
Answer to Civil lawsuit with counterclaim-Marriage and Divorce
Used this document when my client was being sued for breach of contract. We filed an answer and counterclaim for breach of contract and libel and slander. We won the case.
Response Appeal Brief
Response filed on an appeal, issue are excessive judgment and statements counsel made during closing
Premise liability and assault Complaint
Complaint against bar owner for failure to provide a safe environment for patron as well as complaint against unknown person who assaulted client
Complaint for Fair Labor Standard Act & Violation of Minimum Wage Act
Defendant Restaurant failed to pay appropriate wage and we sued on behalf of waiter. Colo. Rev. Stat § 8-6-101, et seq.
Conservator’s Motion to Distribute Funds for College Expenses
Minor settlement funds were placed in protection account, Minor was heading to college and needed money released
Complaint and Jury Demand (personal injury)
Complaint and Jury Demand (personal injury)
Complaint and Jury Demand (bad faith)
Complaint and Jury Demand (bad faith)
Plaintiff’s Motion to Strike Testimony
Plaintiff’s Motion to Strike Testimony
Plaintiff Objection to Motion in Limine – Insurance Law
Plaintiff response to motion to include insurance name in voir dire
Defendant’s Motion In Limmne to Exclude Any & All Evidence That Was Not Properly Disclosed
Civil case where opposing party did not properly disclose witnesses and exhibits prior to jury trial.
Unopposed Motion for Extension of Time to Complete Defendant’s Disclosure
UNOPPOSED MOTION FOR EXTENSION OF TIME TO COMPLETE DEFENDANTS’ C.R.C.P. 26(a)(2) DISCLOSURE AND CERTIFICATE OF COMPLIANCE WITH C.R.C.P. 121 (c) §1-11 AND 1-12(5)
Respondent – Appellee’s Answer Brief
A Denver hearing Board appeal where we won the Career Service Board Hearing regarding my client discipline. Discipline was overturned and City appealed