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Motion for Substitution and Leave to Amend rev (FINAL)
Mot for Substitution and Leave to Amend rev (FINAL)
Motion in Limine re expert testimony by lay witness
Motion in Limine re expert testimony by lay witness
MOTION IN LIMINE RE: APPRAISAL TESTIMONY
MOTION IN LIMINE RE: APPRAISAL TESTIMONY
MOTION IN LIMINE RE: COLLATERAL ESTOPPEL
MOTION IN LIMINE RE: COLLATERAL ESTOPPEL
Motion in Limine to Preclude reference to minors’ damages
Motion in Limine to Preclude reference to minors’ damages
Motion in Limine to Preclude vouching
Motion in Limine to Preclude vouching
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 to For Extension of Time to File answer to Amended Complaint
Motion to For Extension of Time to File answer to Amended Complaint
Motion to Lift Stay of Proceedings-Landlord and Tenant
Motion to lift stay of proceedings in a county court eviction/FED case. For use where defendant files for bankruptcy after judgement for possession, but before writ of restitution is executed. Not applicable if defendant filed their bankruptcy properly, with required certification and posted rent payments with bankruptcy clerk. In that case, see my bankruptcy Motion for Relief for Stay.
Motion to Present Witness by Telephone
Motion to Present Witness by Telephone
Motion to Quash Service Pursuant–Landlord and Tenant
A Motion to Quash Service in a FED (Eviction) case, where Plaintiff failed to follow Rule 304 regarding proper service of a Complaint and Summons. While it may seem so, the Defendants were not married, nor were they otherwise related. As the Rule requires service in this instance separately on each, even had Plaintiff properly served one tenant, he did not properly serve the other.