Motion to Modify Parental Responsibilities, Parenting Time and Child Support
Filed this motion when the court ordered the mother to be the primary parent and gave father some parenting time and ordered father to pay child support. However child continued to reside with father and mother had little parenting time. So filed Motion to modify from the time of the voluntary change pursuant to C.R.S 14-10-122 so that child support can also be modified from date of voluntary change.
Plaintiff’s Unopposed Motion for Leave to File Brief in Excess of Ten Pages
Plaintiff’s Unopposed Motion for Leave to File Brief in Excess of Ten Pages
Plaintiff’s Response to Defendant’s Motion for Summary Judgment
Plaintiff’s Response to Defendant’s Motion for Summary Judgment
DEFENDANTS’ RESPONSE IN OPPOSITION TO PLAINTIFFS MOTION FOR ATTORNEY FEES AND COSTS AND REQUEST FOR HEARING
A sample response to request for attorney fees including a request for a hearing on the attorney fees matter.
JDF 1418 Verified Motion Concerning Parenting Time Disputes
JDF 1418 Verified Motion Concerning Parenting Time Disputes
Memorandum in Support of Motion in Limine to Exclude Alleged Other Acts of Evidence
Memorandum in Support of Motion in Limine to Exclude Alleged Other Acts of Evidence
NOTICE OF MOTION AND MOTION TO QUASH GOVERNMENT’S SUBPOENA COMPELLING THE RELEASE OF INFORMATION FROM DEFENDANT’S GOOGLE ACCOUNT
NOTICE OF MOTION AND MOTION TO QUASH GOVERNMENT’S SUBPOENA COMPELLING THE RELEASE OF INFORMATION FROM DEFENDANT’S GOOGLE ACCOUNT
Hearsay Medical Records, Motion in Limine Precluding
MIL to Preclude Hearsay testimony reading of medical records
Attorney Referral to Doctor, Motion in Limine to Preclude Mention
Motion in Limine to Preclude Mention that Plaintiff was referred to doctor by Attorney
Defendant’s Motion to Dismiss the Complaint/Information
Defendant’s Motion to Dismiss the Complaint/Information
Affidavit of Attorney’s Fees & Costs on Motion to Compel
AFFIDAVIT OF ATTORNEY’S FEES AND COSTS on motion to compel
Motion to Suppress – Traffic & DUI
There was no probable cause for a traffic stop for a violation of Florida Statute § 316.089(1) as Officer — did not see Defendant place any other vehicles in danger nor did Officer — observe a driving pattern giving rise to a suspicion of impairment. As such, all evidence seized as a result of the illegal traffic stop must be suppressed as fruit of the poisonous tree.
Defendant’s Motion to Introduce Evidence (Sex Crimes)
A Motion to peirce/overcome the Colorado Rape Shield Motion. Sets forth specific facts that a defendant may seek to introduce at trial, but that pursuant to the Colorado Rape Shield Motion is otherwise excluded at trial. Motion must be submitted with the accompanying affidavit under seal at least 35 days prior to trial. – Pursuant to 18-3-407 CRS
Motion for Extension of Time to File Answer or Other Respond to Complaint
A motion for extension of time to file and answer or respond to complaint in a civil action, with a proposed order