Civil Litigation
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Complaint: Class Action for Civil Rights Violations Under Title VII Discrimination
A 34 page complaint filed against a City for a pattern of practice of discrimination against Police Officer based on race. Failure to promote, hire and disciplined employees in violation of Title VII
Subject Matter Jurisdiction Brief
Interpleader case where determination was to be made as to who was entitled to life insurance proceeds. Once insurance deposited funds to registry of court they were allowed to withdraw from case and there was no longer an issue of diversity for jurisdiction so court required brief as to why jurisdiction and venue was proper in federal court. Used in Colorado US Federal District court but may be used in all federal courts
Motion to Avoid Judicial Lien
THE DEBTOR, by and through counsel Martinez, Law Firm, LLC, moves this court to avoid judicial lien by stating as follows:
1. Debtor commenced this case on October 19, 2011 by filing a voluntary petition for relief under Chapter 7 of Title 11 of the United States Code.
2. The debtor owns real property occupied as his home located at 5943 S. Tempe Way, Aurora, CO 80015, Arapahoe County Colorado. The debtor believes that the value of the homestead is $224,000 as stated in his schedules.
3. Pursuant to 28 USC 1334, this court has jurisdiction over this motion filed under 11 USC 522(f) to avoid and cancel three judicial liens, to wit:
Complaint to Determine Dischargeability of Debt Persuant to 11 U.S.C. 523(a)
A couple filed a bankruptcy against my client and since my client believed they perpetrated fraud against my client I filed this complaint in federal court to stop the bankruptcy from affecting my clients claims.
Breach of Contract/ Breach of Warranty and Implied Warranty
I used this complaint in a successful lawsuit against a contractor that did not perform his duty as hired. Work was not done in a professional manner, filed this complaint and won a jury trial.
Brief on Motion for Summary Judgment on Breach of Contract/excessive lien
Great brief on a breach of construction contract claim and lien, where my client was claiming the lien filed was excessive
Answer to Mechanics Lien with Affirmative Defenses
Answer that was filed in a multi million dollar lawsuit where the claims where breach of contract and Equitable relief and Lien Foreclosure
Motion for Immunity CO Make My Day Law
DEFENDANT’S MOTION FOR IMMUNITY PURSUANT TO §18-1-704.5 C.R.S.
Consent to Implement Direct Assignment Civil Cases to Full-Time Magistrate
CONSENT FORM PURSUANT TO PILOT PROGRAM TO IMPLEMENT THE DIRECT ASSIGNMENT OF CIVIL CASES TO FULL TIME MAGISTRATE JUDGES
Federal Lawsuit for Discrimination
Complaint in Colorado Federal District Court for Civil Rights Violations and Retaliation. Title VII complaint based on Sexual Harassment.
Answer to Lawsuit for Auto Accident Case
Simple answer to lawsuit for auto accident
Complaint for Fair Labor Standard Act
Complaint under the fair labor standard act for failure to pay overtime and retaliation