Plaintiff’s Response to Defendant’s Motion for Summary Judgment and Brief in Support Thereof
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PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT AND BRIEF IN SUPPORT THEREOF on SEX-BASED HOSTILE WORKING ENVIRONMENT
Motion for new trial regarding DUI case on grounds identification was not requested before arresting defendant.
Motion to the Board of Immigration Appeals to reconsider the USCIS revocation of a marriage based Form I-130 Petition for Alien Relative. Legal Argument: Impermissible revocation, proper legal standard for good faith marriage, petitioner's burden to show bona fide marriage, proper evidentiary standard.
MOTION FOR EXTENSION OF TIME TO SERVE COMPLAINT
Defendant's Emergency Motion for Temporary Release to Attend Funeral
PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION IN LIMINE RE: DEFENDANT’S INJURIES
MOTION FOR MODIFICATION OF CONDITIONS OF DEFENDANT’S BOND
Motion to Permit Amending Complaint to Allege Punitive Damages
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…
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…
Motion for Declaratory Judgment Regarding Validity of Pre-Nuptial Agreement
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…
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…