Brief in Support of Defendant Motion to Dismiss & Motion for More Definite Statement
Motion to dismiss in a lien case and breach of contract case that was filed by contractor to get paid for alleged work performed.
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.
Plaintiff’s Motion for Class Certification Pursuant to FED. R. CIV. P. RULE 23
Motion to Class Certification in Employment Discrimination Lawsuit
Plaintiff’s Respoonse to Defendants’ Rule 12(b)(6) Motion to Dismiss
A Response to a Motion to Dismiss on Class Action Employment Discrimination Case. Lawsuit against city for discrimination against Hispanic police officers
Motion to Avoid Judicial Lien
THE DEBTOR, by and through counsel Martinez, Law Firm, LLC, moves this court to avoid judicial lien by stating as follows:
1. Debtor commenced this case on October 19, 2011 by filing a voluntary petition for relief under Chapter 7 of Title 11 of the United States Code.
2. The debtor owns real property occupied as his home located at 5943 S. Tempe Way, Aurora, CO 80015, Arapahoe County Colorado. The debtor believes that the value of the homestead is $224,000 as stated in his schedules.
3. Pursuant to 28 USC 1334, this court has jurisdiction over this motion filed under 11 USC 522(f) to avoid and cancel three judicial liens, to wit:
Motion to Dismiss for Lack of Jurisdiction
COMES NOW, Martinez Law Firm, LLC, behalf of Defendant, Marisa Aranda, and hereby submits this Motion to Dismiss for Lack of Jurisdiction by stating as follows:
1. On January 5, 2015, Defendant, Marisa Aranda was issued a Uniform Summons and Complaint or Penalty Assessment alleging driving under the influence, DUI per se, failure to present insurance and failure to obey a traffic signal. See attached Exhibit 1. In the Summons the officer states the offenses as alleged occurred in Arapahoe County, CO. The Colorado State Patrol Case Report also states the alleged offenses occurred in Arapahoe County, See attached Exhibit 2.
Entry of Appearance, Motion for Discovery, Waiver of Arraignment, Request for Pre-trial Conference
COMES NOW, Martinez Law Firm, LLC, who enters their appearance on behalf of Defendant, Marisa Aranda, and hereby waives arraignment/first appearance set for March 11, 2015, requests a pretrial conference with the Arapahoe County District Attorney at a mutually agreeable time, and requests an Order directing the prosecuting attorney to immediately provide discovery of the following material relevant to this case:
Motion for Reconsideration on child Support Order and or Abatement
Child Support issue where client was over charged by a court order on child support. We requested reconsideration and credit for support already paid with the proposed order
Motion to Modify Maintenance
A Simple one page Motion to Modify maintenance filed in Boulder County Colorado
Motion to Modify Parenting Time
In depth Motion to Modify Parenting Time and Parental Responsibilities. A Post Decree motion claiming that the current orders are to restrictive and custodial parent is alienating parent from child.
Motion for a forthwith hearing and Interim Orders
Filed a motion when parent was refused normal parenting time as ordered by the court.
Motion for Judicial Review – Child Custody
A motion filed to review a magistrates decision. Filed after magistrate entered order client disagreed with. A lengthy and difficult custody case
Motion to Continue Trial
A simple motion to continue a trial in misdemeanor case when Attorney was just recently hired
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
Motion in Limine (Victim)
DEFENDANT’S MOTION IN LIMINE TO PROHBIT THE USE OF THE TERM VICTIM AT TRIAL