Motion to Reconsider and Reopen Record
Motion to Reopen Immigration Court testimony based upon Respondent’s incompetency. Respondent became confused during testimony due to a traumatic brain injury which caused serious cognitive defects and memory and confusion issues. Motion requested that Court reopen the record and take additional testimony of Respondent’s lack of competence.
Motion for Judgment not withstanding the verdict or Motion for New Trial
Judgment was entered against my client. We filed a motion based on the evidence for a new trial or in the alternative a Motion Not Withstanding the Verdict. My client was held liability for Outrageous Conduct and emotion distress
BIA Motion to Reconsider I-130 Revocation
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.
PLAINTIFFS’ RESPONSE TO DEFENDANT’S MOTION FOR CLARIFICATION OF ORDER RE: HYPOTHETICAL SETTLEMENT SCENARIOS
PLAINTIFFS’ RESPONSE TO DEFENDANT’S MOTION FOR CLARIFICATION OF ORDER RE: HYPOTHETICAL SETTLEMENT SCENARIOS
PLAINTIFFS’ RESPONSE IN OPPOSITION TO DEFENDANT’S THIRD MOTION IN LIMINE REGARDING RIGHTS VERSUS DUTIES
Plaintiff’s response in opposition to defendant’s third motion in limine regarding rights versus duties.
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S SIXTH MOTION IN LIMINE REGARDING
Plaintiff’s response to defendant’s sixth motion in limine regarding expert.
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S SECOND MOTION IN LIMINE REGARDING PEV AND RESERVE INFORMATION
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S SECOND MOTION IN LIMINE REGARDING PEV AND RESERVE INFORMATION. |
PLAINTIFFS’ RESPONSE IN OPPOSITION TO DEFENDANT’S FOURTH MOTION IN LIMINE REGARDING
Plaintiff’s response in opposition to defendant’s fourth motion in limine regarding expert.
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S FIRST MOTION IN LIMINE REGARDING HYPOTHETICAL SETTLEMENT SCENARIOS
Plaintiff’s response in opposition to defendant’s first motion in limine regarding hypothetical settlement scenarios.
PLAINTIFFS’ RESPONSE TO DEFENDANT’S FIFTH MOTION IN LIMINE REGARDING MILLER VALUATIONS
PLAINTIFFS’ RESPONSE TO DEFENDANT’S FIFTH MOTION IN LIMINE REGARDING MILLER VALUATIONS. |
PLAINTIFFS’ REPLY IN SUPPORT OF MOTION TO AMEND COMPLAINT TO INCLUDE A PRAYER FOR EXEMPLARY DAMAGES
PLAINTIFFS’ REPLY IN SUPPORT OF MOTION TO AMEND COMPLAINT TO INCLUDE A PRAYER FOR EXEMPLARY DAMAGES |
PLAINTIFFS’ REPLY IN SUPPORT OF MOTION IN LIMINE RE: DEFENDANT’S “OPPORTUNITY TO SETTLE”
Plaintiff’s reply in support of motion in limine RE: defendant’s “opportunity to settle”.
PLAINTIFFS’ MOTION TO AMEND COMPLAINT TO INCLUDE A PRAYER FOR EXEMPLARY DAMAGES
Plaintiff’s motion that requests that the court enter an order permitting them to amend their complaint to include a prayer for exemplary damages.
PLAINTIFFS’ MOTION IN LIMINE RE: DEFENDANT’S “OPPORTUNITY TO SETTLE”
Plaintiff’s motion in limine Re: Defendant’s “opportunity to settle”