Brief arguing that certain gang based and domestic sexual violence based claims still qualify as a particular social group membership for purposes of asylum post Matter of A-B-. Also argues that certain conclusions reached in Matter of A-B- are flawed and contradict current caselaw.
RETALIATORY DISCHARGE IN VIOLATION OF THE FAMILY AND MEDICAL LEAVE ACT, WRONGFUL TERMINATION BASED ON DISABILITY DISCRIMINATION, FAILURE TO PROVIDE REASONABLE ACCOMMODATION
Complaint for Disability Discrimination, Sex Discrimination, Retaliation
A employment contract for a bilingual receptionist or secretary. The contract include employer providing phone for remote receptionist to answer. Termination and return of property are also included in the terms of the contract. State can easily be changed to use in any state or jurisdiction
Motion to dismiss filed by defendant (officers) based on qualified immunity
Motion to modify scheduling order to exclude individuals from carrying firearms in deposition
A partial stipulated motion for protective orders in an excessive force case
Motion for leave to file excessive pages to a response to a motion to dismiss
PLAINTIFF’S MOTION FOR ATTORNEYS’ FEES PURSUANT TO 42 U.S.C. § 1988
PLAINTIFF’S MOTION TO EXCLUDE EVIDENCE OF ALLEGED CODE VIOLATIONS DISCOVERED AFTER AUGUST 2013
PLAINTIFF’S MOTION TO EXCLUDE EVIDENCE OF ALLEGED CODE VIOLATIONS DISCOVERED AFTER AUGUST 2013
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT AND MOTION TO DISMISS
UNOPPOSED MOTION FOR LEAVE TO TAKE THE DEPOSITION OF AFTER DISCOVERY CUT-OFF
DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT AND MOTION TO DISMISS