Litigation
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Answer
A sample answer defending a claim against the federal wage statues.
Order to Show Cause for Change of Name
Order to Show Cause for Change of Name
Order to Show Cause for Change of Name (Change of Name)
Order to Show Cause for Change of Name (Change of Name)
Order on Application to File Documents Under Seal in Name Change Proceeding Under Address Confidentiality Program (Safe at Home)
Order on Application to File Documents Under Seal in Name Change Proceeding Under Address Confidentiality Program (Safe at Home)
Order for Change of Gender and Issuance of New Birth Certificate
Order for Change of Gender and Issuance of New Birth Certificate
Request to File New Litigation by Vexatious Litigant
Request to File New Litigation by Vexatious Litigant
Prefiling Order–Vexatious Litigant
Prefiling Order–Vexatious Litigant
Plaintiff’s Objection and Request for Hearing on Defendant’s Motion for Fees and Bill of Cost
PLAINTIFFS’ OBJECTION AND REQUEST FOR HEARING ON DEFENDANTS’ MOTION FOR FEES AND BILL OF COSTS
Procedural Objection to Defendant’s Motion – Missed Deadline
PROCEDURAL OBJECTION TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT MISSED DEADLINE
Plaintiff’s Objection to Computer Expert & Request for Shrek Hearing
PLAINTIFF’S OBJECTION TO DEFENSE COMPUTER “EXPERT” REQUEST FOR SHREK HEARING
Motion for Attorney’s Fees Pursuant-Landlord and Tenant
A Motion for an award of attorney’s fees in a civil FED case. Filed under 13-17-101 CRS, seeking the award for a substantially frivolous, groundless, and/or vexatious action and/or pleading. Fact specific, but a good starting point in any request for fees. It was ultimately denied as the defendant “was not aware of the possibility of an award of attorney’s fees” under 13-17-102(6), despite having had several discussions about exactly that on the record.
Plaintiff’s Motion to Strike Testimony
Plaintiff’s Motion to Strike Testimony
Response Brief to Motion for Summary Judgment
Insurance interpleader case where there was a dispute as to who gets a life insurance policy. I represented the name beneficiary and the other party was the descendants two daughters. The daughters claimed they were entitled to insurance proceeds because he was required to pay child support. This my response to their motion for summary judgment.
Plaintiffs Response to Defendants Motion to Strike Plaintiffs Motion to Compel
Plaintiffs Response to Defendants Motion to Strike Plaintiffs Motion to Compel
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Employee Handbook
This product states the changes in policy, employment-at-will, and employment policies, such as, employee classifications, equal employment opportunity, confidentiality, employment of minors, employment of relatives, personnel records and employee references, privacy, immigration law compliance, and political neutrality. It also states the hours of work and payroll practices, such as, pay periods and paydays, overtime, rest and meal periods, time cards, payroll deductions, wage garnishment, direct deposit, Fair pay act. It also states the standards of conduct and employee performance, such as, anti-harassment and discrimination, attendance, discipline and standards of conduct, dress code, safety, substance and abuse, workplace searches, internet and computer use policy and cell phone policy. Also states the employee benefits and services, including, group health insurance, 401(k) plan, COBRA, worker’s compensation, FICA, and unemployment insurance. Lastly it states employee leaves of absence and time off, including, sick days, healthy workplace healthy family acct, paid family leave benefits, notice of domestic violence leave and accommodation rights, family and medical leave, workers’ compensation leave, bereavement leave, jury duty and voting time.