Affidavit in Support of Motion to Modify Allocation of Parental Responsibilities
AFFIDAVIT IN SUPPORT OF MOTION TO MODIFY ALLOCATION OF PARENTAL RESPONSIBILITIES
Motion for Discovery & Inspection of Evidence
MOTION FOR DISCOVERY AND INSPECTION OF EVIDENCE
Motion to Dismiss – Civil Litigation
Plaintiffs’ claims for fraudulent and negligent misrepresentation fail because the Defendants did not know of the allegedly misrepresented conditions. Furthermore, Plaintiffs were not justified in relying upon the representations made by the defendants. To the extent the purported defects existed at the time of contracting, they were open and obvious and could have been detected through reasonable diligence. Plaintiff’s breach of contract claim fails because there is no genuine dispute that the defendants did not have actual knowledge of the presence of bats under the roof tiles on the house. Accordingly, they did not breach a contractual duty owed to Plaintiffs as prescribed by the Seller’s Property Disclosure form. Plaintiffs’ claim for civil conspiracy likewise fails because the defendants have not committed an unlawful act.
Defendant’s Motion to Introduce Evidence (Sex Crimes)
A Motion to peirce/overcome the Colorado Rape Shield Motion. Sets forth specific facts that a defendant may seek to introduce at trial, but that pursuant to the Colorado Rape Shield Motion is otherwise excluded at trial. Motion must be submitted with the accompanying affidavit under seal at least 35 days prior to trial. – Pursuant to 18-3-407 CRS
Motion to Return Property
Client was arrested and charged with illegal possession of a firearm and drug possession. Police also confiscated $4,000.00 in cash. We filed motion to return the cash as it is not relevant to the charges. further client needs money to help his defense.
Response to Motion to Vacate a Default Judgment & Motion to Strike Answer
Great response to a Defendant who failed to file an answer and then after judge ordered default, defendant filed a motion to vacate the default and a motion to leave to file an answer.
Motion for Extension of Time to File Answer or Other Respond to Complaint
A motion for extension of time to file and answer or respond to complaint in a civil action, with a proposed order
Brief in Support to Motion to Dismiss (Patent Law)
A 12B brief in support for a motion to dismiss for patent infringement
Motion to Reopen & Request for Stay of Removal – Immigration Law
Motion to Reopen & Request for Removal – Immigration Law
Motion to Administratively Close Proceedings – Immigration Law
Motion to Close Proceedings – Immigration Law
Motion to Continue – Immigration Law
Motion to Continue – Immigration Law
Motion for Suppression of Evidence – Immigration
Motion for Suppression of Evidence – Immigration
Complaint for Improper Foreclosure – Georgia
The judicial foreclosure process starts when a lender sues a delinquent borrower in the county where the property is located. To initiate the suit, the lender (the plaintiff) files a document called a “complaint for foreclosure” or “petition for foreclosure” in court. Plaintiff’s complaint for breach of contract, failure to provide notice pursuant to the security deed and failure to act in good faith and fair dealing regarding plaintiff’s loan modification and terms of the security deed, violation of Georgia Fair Lending Act, wrongful foreclosure, negligence, emotional distress, punitive damages, attorney’s fees and expenses.
Defendant’s Motion for County to Pay for Statement of Facts
DEFENDANT’S MOTION FOR _______________ COUNTY TO PAY FOR STATEMENT OF FACTS
Motion for Deposition (Criminal)
A Motion under CRCP 15 for a deposition of an invaluable witness to preserve testimony. As can be seen, the alibi witness was elderly and in very poor health, so we needed to preserve her testimony. Did not actually get to that point as the DA made a very favorable offer, which was accepted, after this motion was filed.