Plaintiff Objection to Motion in Limine – Insurance Law
Plaintiff response to motion to include insurance name in voir dire
Defandant’s Motion to Intervene – Construction Law
CONCRETE CORP’S MOTION TO INTERVENE in mechanics lien
Motion to Schedule ADR Without Participation of Petitioner
MOTION TO SCHEDULE ADR WITHOUT THE PARTICIPATION OF PETITIONER
Motion for Sanctions for Failure to Provide Discovery
Motion for Sanctions under discovery rules (Rule 16 in Colorado), for prosecution’s repeated failure to provide specific police reports as required. The case settled prior to litigating this issue, though the plea agreement was much better than it could have been largely because of this issue.
Motion for Extension of Time to Complete Service of Process and Proposed Order
Motion for Extension of Time to Complete Service of Process and Proposed Order
Unopposed Motion to Appear by Telephone and Proposed Order-Marriage and Divorce
Unopposed Motion to Appear by Telephone and Proposed Order-Marriage and Divorce
Motion for Judicial Default-Marriage and Divorce
Motion for Judicial Default-Marriage and Divorce
Motion for Inventory of Business and Accounting of Liquidation Proceeds-Marriage and Divorce
I used this motion to compel an inventory of business assets, accounting of the liquidation proceeds and to have the proceeds held pending an agreement or court order.
Defendant’s Motion In Limmne to Exclude Any & All Evidence That Was Not Properly Disclosed
Civil case where opposing party did not properly disclose witnesses and exhibits prior to jury trial.
Motion to Hold Child Support and Health Insurance Payments in the Registry of the Court
Since the court cannot suspend the child support while the Petition to Disestablish Paternity is pending, I use this motion to have the child support held in the registry of the court until a final order disestablishing paternity is entered which could save the client thousands of dollars.
Unopposed Motion for Extension of Time to Complete Defendant’s Disclosure
UNOPPOSED MOTION FOR EXTENSION OF TIME TO COMPLETE DEFENDANTS’ C.R.C.P. 26(a)(2) DISCLOSURE AND CERTIFICATE OF COMPLIANCE WITH C.R.C.P. 121 (c) §1-11 AND 1-12(5)
Entry of Apprearance & Motion for Leave of the Court to File Answer & Cross-claim
Represented a name defendant
Verified Motion for an Order for Service by Publication
VERIFIED MOTION FOR AN ORDER FOR SERVICE BY PUBLICATION