Civil Litigation
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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.
Plaintiff’s Motion for Class Certification Pursuant to FED. R. CIV. P. RULE 23
Motion to Class Certification in Employment Discrimination Lawsuit
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)
Motion to Dismiss – Wrongful Death Action
Motion to Dismiss – Wrongful Death Action
Motion for Independent Med Exam Pursuant to C.R.C.P. 35(a) + Ruling
A response to a motion for independent medical examine in a personal injury cases. After any kind of accident, the first medical treatment is often performed by a doctor of the injured person’s own choosing (maybe even their own physician). Naturally, when a personal injury claim is filed over the accident, the defendant (or their insurance company) will want a second opinion and may request an IME. In general, an IME is performed by a licensed doctor of medicine (MD) or doctor of osteopathic medicine (OD), usually one with medical knowledge or training in the specific area relating to the case, and with experience in the area of IMEs.
Plaintiffs Motion for Class Certification
PLAINTIFFS’ MOTION FOR CLASS CERTIFICATION PURSUANT TO FED. R. CIV. P. RULE 23
Motion For Extension of time to file Answer
Motion for Extension time to file answer
Motion to Strike – Federal Court
PLAINTIFF’S MOTION TO STRIKE ARGUMENTS RAISED FOR FIRST TIME IN REPLY, OR IN THE ALTERNATIVE, FOR LEAVE TO FILE SURREPLY
Motion to Dismiss – Lack of Personal Jurisdiction
MOTION TO DISMISS FOR LACK OF PERSONAL JURISDICTION PURSUANT TO FED. R. CIV. P. 12(b)(2)
Motion to Strike a New Affidavit
PLAINTIFF MOTION TO STRIKE THE NEW AFFIDAVIT, EXHIBITS, AND ARGUMENTS ON WHICH DEFENDANT RELIES IN ITS REPLY, OR, IN THE ALTERNATIVE, FOR LEAVE TO FILE A SURREPLY
Motion in limine that defendant did not recive ticket
In a auto accident case plaintiff filed motion to limit the defense from mentioning that defendant did not get a ticket
PLAINTIFF’S MOTION FOR JUDGMENT ON THE PLEADINGS AND MEMORANDUM IN SUPPORT
In a Fair Debt Collection Act PLAINTIFF’S MOTION FOR JUDGMENT ON THE PLEADINGS AND MEMORANDUM IN SUPPORT
Motion to Compel
compelling disclosure of the mandatory disclosure documents required by C.R.C.P. 16.2(e).
UNOPPOSED MOTION FOR LEAVE TO FILE AMENDED COMPLAINT
UNOPPOSED MOTION FOR LEAVE TO FILE AMENDED COMPLAINT