Motion for Scientific Paternity Testing
Motion used to compel paternity testing to show he is or is not the biological father.
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
Entry of Appearance & Motion To Continue Preliminary Hearing Set
A standard entry of appearance and motion to continue a preliminary hearing due to the attorney not being available for the hearing.
Plaintiff Response To Defendants City Motion for Summary Judgement in Title VII Case
Plaintiff response to summary judgment on a discrimination case against a city employer
Verified Motion for an Order for Service by Publication
VERIFIED MOTION FOR AN ORDER FOR SERVICE BY PUBLICATION
Motion for State Witnesses to Discuss Facts with Defense Counsel
MOTION FOR AUTHORIZATION FOR STATE’S WITNESSES TO DISCUSS FACTS OF THE CASE WITH DEFENSE COUNSEL
Motion to modify child support
Represented Father asking for reduction child support due to the fact that one of the children moved in with him. Voluntary Change of parenting time. In order to reduce your child support payments, you must petition the court and allow a judge to make a decision. This is usually referred to as filing a motion to modify child support. This process can vary slightly from state to state, but the general procedure is the same.
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.
Combine Motion For Reconsideration Motion For Forthwith Hearing And Emergency Interim Orders
Drafted this motion after a court granted a party interim orders taking all custody away from mom. Child was taken away from mom and she had not seen child for several weeks
Response to Summary Judgment for Excessive Force Complaint (Police)
filed this response to a motion for summary judgment in a federal excessive force claim
Respondent’s Verified Motion to Modify Allocation of Parenting Time
A post decree motion to modify parenting time and child support based on one parent not taking or using his time with one of the children.
PURSUANT TO C.R.S. § 14-10-129  AND MOTION TO MODIFY CHILD SUPPORT PURSUANT TO C.R.S. § 14-10-122 and C.R.S. § 14-10-115
Response to motion to Dismiss
A Response to motion to Dismiss in a Title VII employment discrimination case. Filed in Colorado US District Court
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.