Motion for Entry of Default Judgment
Second part of entering a default judgment is the request for the actual judgment. first file a motion for default by the clerk. then file the motion for Default judgment, request the exact damages and include specific language as required by statute.Â
The Colorado Method of Voir Dire
This product states the overview of the Colorado method of Voir Dire, which includes, a discussion of indictment, emotionally difficult nature of the evidence and allegations, learning prospective jurors’ views about life and death, re-stripping the prospective juror, questioning to challenge, exploring unique aspects of decision-making, and factual determination versus moral decision.
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 to Administratively Close Proceedings
Motion to Immigration Court requesting administrative closure under Matter of Avetisyan based upon humanitarian grounds and low priority for removal.
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.
Response To motion for Extension of Time to Pay Property Distribution in Divorce
client was owed money from a divorce in property distribution. wife was to pay husband $85,000.00 wife paid some but was requesting more time to pay the additional money. We filed this objection and argued the alternative that my client be granted 8% interest from time of divorce if court does grant her the motion for extension of time to pay the husband
Motion to Abate and Modify Child Support
Motion to abate and modify child support
Motion to move forward with default
A motion I filed after I filed a motion to modify decision making and parenting time. Respondent never answered and failed to appear for mediation. So I filed a request for court to enter a default against the Respondent
DEFENDANT’S REPLY IN SUPPORT OF THIRD MOTION IN LIMINE REGARDING RIGHTS VERSUS DUTIES
Defendant’s reply in support of third motion regarding rights versus duties owed by defendant.Â
DEFENDANT’S REPLY IN SUPPORT OF SIXTH MOTION IN LIMINE REGARDING NAMES
Defendant’s reply in support of their sixth motion regarding the testimony of the expert. This motion asks the court to prevent plaintiffs from introducing evidence, testimony, or opinion from the Judge.
DEFENDANT’S REPLY IN SUPPORT OF FOURTH MOTION IN LIMINE REGARDING ATTORNEY’S NAME
Defendant’s reply in support motion regarding conduct, advice, actions or inaction of the attorney.Â
DEFENDANT’S MOTION FOR SUMMARY JUDGMENT
Defendant’s pursuant to C.R.C.P. 56, makes the following motion for summary judgement: pursuant to C.R.C.P 121, undersigned counsel certifies conferral with counsel for plaintiff who objects to the relief requested in this motion.Â