Real Estate
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Reply re Motion to Dismiss for Failure to Fulfill Condition Precedent
Reply re Motion to Dismiss for Failure to Fulfill Condition Precedent
Reply re Motion for Partial Summary Judgment
Reply re Motion for Partial Summary Judgment
Reply re Motion for Attorney Fees and Costs
Reply re Motion for Attorney Fees and Costs
Response to Rule 120 Notice-Landlord and Tenant
JDF 621 Response to Rule 120 Notice.doc
Response in Opposition to Defendant + Motion for Allocation of Damages
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT MOTION FOR ALLOCATION OF DAMAGES
Motion for Absentee Testimony – Landlord Tenant
Motion seeking to allow testimony via telephone for out of state witnesses/litigants.
Breach of Contract/ Breach of Warranty and Implied Warranty
I used this complaint in a successful lawsuit against a contractor that did not perform his duty as hired. Work was not done in a professional manner, filed this complaint and won a jury trial.
Affidavit for Transfer of Property on Death of a Relative
This form is an Affidavit required to be filled out by the surviving spouse in order to transfer martial real estate that was titled in both names as individuals, but lacked a designation. This form must accompany the actual Transfer Of Death Deed, marriage certificate and death certificate of the deceased spouse.
Motion to Dismiss FED Case-Landlord and Tenant
Motion to Dismiss a FED case for lack of proper service and improper pleading. Ultimately, it worked, but the court still required a hearing.
Motion to Quash Service Pursuant–Landlord and Tenant
A Motion to Quash Service in a FED (Eviction) case, where Plaintiff failed to follow Rule 304 regarding proper service of a Complaint and Summons. While it may seem so, the Defendants were not married, nor were they otherwise related. As the Rule requires service in this instance separately on each, even had Plaintiff properly served one tenant, he did not properly serve the other.