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Verified Motion for an Order for Service by Publication
VERIFIED MOTION FOR AN ORDER FOR SERVICE BY PUBLICATION
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.
Excessive Force Against Sheriff Department -42 U.S.C. §1983
Complaint filed against a sheriff department for excessive force.
Open Public Record Request Letter
A open letter request to City requesting police activity at a local bar/establishment
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.
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.
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
Breach of Contract/ Breach of Warranty and Implied Warranty
I used this complaint in a successful lawsuit against a contractor that did not perform his duty as hired. Work was not done in a professional manner, filed this complaint and won a jury trial.
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
Answer to Mechanics Lien with Affirmative Defenses
Answer that was filed in a multi million dollar lawsuit where the claims where breach of contract and Equitable relief and Lien Foreclosure
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