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Motion for Brief for Summary Judgment and Dismissal of Defendant Foulk’s Second Counterclaim
MOTION & BRIEF FOR SUMMARY JUDGMENT AND DISMISSAL OF DEFENDANT FOULK’S SECOND COUNTERCLAIM: “(Retaliation—Title VII—42 U.S.C. § 2000e-2)” MOTION TO STRIKE RELATED SECOND COUNTERCLAIM AVERMENTS
C.R.C.P. 12(f) MOTION FOR ATTORNEY FEES & COSTS C.R.S. §§ 13-17-102, 13-16-104, and C.R.C.P. 11
Defendants Motion for Summary Judgment – Employment Law
Brief and motion for summary judgment Title VII Discrimination, (2) Wrongful Discharge in Violation of Public Policy as set forth in the Colorado Anti-Discrimination Act, C.R.S. 24-34-402, and (3) Violation of the Colorado Wage Claim Act, C.R.S. 8-4-101.
Plaintiff’s Motion for Attorney Fees
After receiving a judgment in employment case Plaintiff is requesting attorney fees as prevailing party
Plaintiff’s Motion for Evidentiary Hearing on Back Pay
PLAINTIFF’S MOTION FOR EVIDENTIARY HEARING ON BACK PAY after receiving a judgment on title VII case
Plaintiff’s Motion to Compel Production of Documents and for Expedited Hearing
PLAINTIFF’S MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND FOR EXPEDITED HEARING in an employment Title vII case
Defendants Motion in Limine Related to Limitations Period
A sample motion by defendant limiting testimony for claims made outside the statue of limitations.
MOTION FOR DISCOVERY ON ATTORNEY FEES
A motion for discovery on a request for attorney fees.
MOTION FOR LEAVE TO AMEND FIRST AMENDED COMPLAINT TO ADD A CLAIM FOR EXEMPLARY DAMAGES
A motion for leave to amend a complaint to add a claim for exemplary damages.
Order to Show Cause
A motion to compel for a party to follow court order and to produce their expert witness’ file.
Order re Motion to Compel Compliance
The courts order on defendant’s motion to compel plaintiff to pay attorney fees.
Plaintiff’s Motion for Liquidated Damages and Statutory Penalties
A motion for liquidated damages and penalties after a jury finds a defendant guilty of violating the fair standard act.
Plaintiffs Unopposed Motion For Enlargement Of Time To Submit Expert Rebuttal Disclosures, Pursuant To C.R.C.P. Rule 6
A motion to request an extension of time to submit expert’s reports.
PLAINTIFFS’ UNOPPOSED MOTION FOR LEAVE TO AMEND COMPLAINT TO JOIN ADDITIONAL PARTY
A sample motion to leave to add an additional party.
Employment Contract for a Bilingual Receptionist & Secretary
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