Civil Litigation
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Amended Complaint & Jury Demand
A complaint filed In Colorado Federal District Court claiming discrimination based on race and for retaliation
Defendant Rule 56 Motion For Summary Judgment (with Attached Brief)
Motion for Summary Judgement in Breach of Contract and Mechanics Lien case. Lawsuit filed by Contractor for payment for service performed and lien case.
Brief in Support of Defendant Motion to Dismiss & Motion for More Definite Statement
Motion to dismiss in a lien case and breach of contract case that was filed by contractor to get paid for alleged work performed.
Findings of Fact & Conclusion of Law in a Contract Dispute & Excessive Mechanics Lien
A 14 page finding of facts and conclusion of law. Contractor sued owner for money owed to them for work performed, Owner counter sued for breach of contract and excessive in lien in Colorado.
Plaintiff Response to Defendants City Motion for Summary Judgement
Response to motion for summary judgement in employment discrimination case. Client is a police officer that was passed over for a promotion.
Plaintiff’s Motion for Class Certification Pursuant to FED. R. CIV. P. RULE 23
Motion to Class Certification in Employment Discrimination Lawsuit
Plaintiff’s Respoonse to Defendants’ Rule 12(b)(6) Motion to Dismiss
A Response to a Motion to Dismiss on Class Action Employment Discrimination Case. Lawsuit against city for discrimination against Hispanic police officers
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
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
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
Complaint for Fair Labor Standard Act
Complaint under the fair labor standard act for failure to pay overtime and retaliation
Declaration in Support of Application to File Documents Under Seal in Name Change Proceeding Under Address Confidentiality Program (Safe at Home)
Declaration in Support of Application to File Documents Under Seal in Name Change Proceeding Under Address Confidentiality Program (Safe at Home)