No “Unavoidable Accident” Defense, Motion in Limine
Motion in limine to preclude an affirmative defense of unavoidable accident
Plaintiff’s Response to Defendant’s Motion for Summary Judgment and Brief in Support Thereof
PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT AND BRIEF IN SUPPORT THEREOF on SEX-BASED HOSTILE WORKING ENVIRONMENT
Motion for a New Trial – DUI Case File
Motion for new trial regarding DUI case on grounds identification was not requested before arresting defendant.
MOTION FOR EXTENSION OF TIME TO SERVE COMPLAINT
MOTION FOR EXTENSION OF TIME TO SERVE COMPLAINT
Defendant’s Emergency Motion for Temporary Release to Attend Funeral
Defendant’s Emergency Motion for Temporary Release to Attend Funeral
Plaintiff’s Response to Defendant’s Motion in Limine RE: Defendant’s Injuries
PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION IN LIMINE RE: DEFENDANT’S INJURIES
MOTION FOR MODIFICATION OF CONDITIONS OF DEFENDANT’S BOND
MOTION FOR MODIFICATION OF CONDITIONS OF DEFENDANT’S BOND
Punitive Damages, Motion for Leave to Amend to Add
Motion to Permit Amending Complaint to Allege Punitive Damages
Motion for Attorney’s Fees Pursuant-Landlord and Tenant
A Motion for an award of attorney’s fees in a civil FED case. Filed under 13-17-101 CRS, seeking the award for a substantially frivolous, groundless, and/or vexatious action and/or pleading. Fact specific, but a good starting point in any request for fees. It was ultimately denied as the defendant “was not aware of the possibility of an award of attorney’s fees” under 13-17-102(6), despite having had several discussions about exactly that on the record.
Motion to Lift Stay of Proceedings-Landlord and Tenant
Motion to lift stay of proceedings in a county court eviction/FED case. For use where defendant files for bankruptcy after judgement for possession, but before writ of restitution is executed. Not applicable if defendant filed their bankruptcy properly, with required certification and posted rent payments with bankruptcy clerk. In that case, see my bankruptcy Motion for Relief for Stay.
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.
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 in Limine Inadmissable Rule 404(B) Evidence – legal document
Motion by Defendant to exclude Plaintiffs from offering evidence founded upon inadmissible evidence under inadmissible evidence. In the past, the Plaintiff, their counsel, and their witnesses have frequently made references.