Civil Litigation
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Motion for Order Imposing Sanctions for Failure to Comply with Order Compelling Discovery
Motion for Order Imposing Sanctions for Failure to Comply with Order Compelling Discovery
Proposed Order Granting Motion to Compel Discovery
Proposed Order Granting Motion to Compel Discovery
Defendant’s Response & Cross-Motion for Judgment on the Pleadings
DEFENDANT’S RESPONSE AND CROSS-MOTION FOR JUDGMENT ON THE PLEADINGS
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 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
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.
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
Defandant’s Motion to Intervene – Construction Law
CONCRETE CORP’S MOTION TO INTERVENE in mechanics lien
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)