Motions
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Motion In Limine for Brief Non-Argumentative Statement Prior to Jury Selection
Motion seeking to give a brief, non-argumentative, opening statement to a jury panel prior to voire dire. Includes constitutional language as well as direction form Chief Justice Directives on such practices.
Complaint for Improper Foreclosure – Georgia
The judicial foreclosure process starts when a lender sues a delinquent borrower in the county where the property is located. To initiate the suit, the lender (the plaintiff) files a document called a “complaint for foreclosure” or “petition for foreclosure” in court. Plaintiff’s complaint for breach of contract, failure to provide notice pursuant to the security deed and failure to act in good faith and fair dealing regarding plaintiff’s loan modification and terms of the security deed, violation of Georgia Fair Lending Act, wrongful foreclosure, negligence, emotional distress, punitive damages, attorney’s fees and expenses.
Affidavit in Support of Motion to Modify Allocation of Parental Responsibilities
AFFIDAVIT IN SUPPORT OF MOTION TO MODIFY ALLOCATION OF PARENTAL RESPONSIBILITIES
Petitioner’s Verified Motion for: Publication by Consolidated Notice
PETITIONER’S VERIFIED MOTION FOR PUBLICATION BY CONSOLIDATED NOTICE for Denver divorce
404B objection
Motion to deny the People’s Notice of Intent to Introduce Res Gestate Evidence or, In the Alternative, of Other Transactions, Pursuant to C.R.S. § 16-10-301 and C.R.E. 404(b).
PLAINTIFFS’ MEMORANDUM IN SUPPORT OF MOTION FOR APPROVAL OF PLAINTIFFS’ PLAN FOR CLASS NOTICE
PLAINTIFFS’ MEMORANDUM IN SUPPORT OF MOTION FOR APPROVAL OF PLAINTIFFS’ PLAN FOR CLASS NOTICE
PLAINTIFF’S MEMORANDUM OF LAW IN SUPPORT OF ITS MOTION FOR A PRELIMINARY INJUNCTION AND EXPEDITED DISCOVERY
PLAINTIFF’S MEMORANDUM OF LAW IN SUPPORT OF ITS MOTION FOR A PRELIMINARY INJUNCTION AND EXPEDITED DISCOVERY for trade secrets claim
DEFENDANT’S MEMORANDUM IN SUPPORT OF ITS MOTION TO DISMISS
PLAINTIFF sued DEFENDANT for breach of contract and misappropriation of trade secrets. PLAINTIFF does not, however, allege that DEFENDANT actually breached the contract nor does it have any evidence whatsoever that he has misappropriated trade secrets.
Notice of Motion to Permit the Inspection and Copying of Items
NOTICE OF MOTION TO PERMIT THE INSPECTION AND COPYING OF ITEMS COVERED BY TEXAS CODE OF CRIMINAL PROCEDURE ARTICLE 39.14
Notice of Motion
AFFIRMATION IN SUPPORT OF CPL 330.30 [1] MOTION
MATERIAL TESTIMONY WAS ERRONEOUSLY EXCLUDED AS INADMISSIBLE HEARSAY
THE COURT FAILED TO PROVIDE THE JURY WITH DEFINITIONS OF
“DEPR IVE” AND “APP ROPR IATE”
THE COURT ERRONEOUSLY ADMITTED ANDREA BANKEMPLOYEE’ S CERTIFICATION OF BANK RECORDS INTO EVIDENCE
Notice of Motion – New York Criminal Law
NOTICE OF MOTION DEFENDANT WAS DENIED THE RIGHT TO PROCEED PRO SE
Notice of Motion & Motion to Dismiss The Complaint
Notice of Motion and Motion to Dismiss the Complaint
MIL: Statements of Co-Defendant or in the Alternative to Sever Defendants
MOTION IN LIMINE RE: STATEMENTS OF CO-DEFENDANT or, in the ALTERNATIVE, TO SEVER DEFENDANTS
Federal Sentencing Memorandum – Wisconsin
Motions-Federal Sentencing Memorandum Wisconsin
Motion for Severance and Memo in Opposition to State’s Motion for Dual Juries
Motion for Severance and Memorandum in Opposition to State’s Motion for Dual Juries