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Motion to Stike Defendant’s Name’s Designations of Non-Party At Fault
Motion to Stike Defendant’s Name’s Designations of Non-Party At Fault
Defandant’s Motion to Intervene – Construction Law
CONCRETE CORP’S MOTION TO INTERVENE in mechanics lien
Motion for Sanctions for Failure to Provide Discovery
Motion for Sanctions under discovery rules (Rule 16 in Colorado), for prosecution’s repeated failure to provide specific police reports as required. The case settled prior to litigating this issue, though the plea agreement was much better than it could have been largely because of this issue.
Motion for Relief From Judgment Pursuant to Fla. R. Civ. P. 1.540
Motion for Relief From Judgment Pursuant to Fla. R. Civ. P. 1.540
Motion for Declaratory Judgment Regarding Validity of Pre-Nuptial Agreement
Motion for Declaratory Judgment Regarding Validity of Pre-Nuptial Agreement
Motion for Extension of Time to Complete Service of Process and Proposed Order
Motion for Extension of Time to Complete Service of Process and Proposed Order
Motion for Inventory of Business and Accounting of Liquidation Proceeds-Marriage and Divorce
I used this motion to compel an inventory of business assets, accounting of the liquidation proceeds and to have the proceeds held pending an agreement or court order.
Defendant’s Motion In Limmne to Exclude Any & All Evidence That Was Not Properly Disclosed
Civil case where opposing party did not properly disclose witnesses and exhibits prior to jury trial.
Motion to Hold Child Support and Health Insurance Payments in the Registry of the Court
Since the court cannot suspend the child support while the Petition to Disestablish Paternity is pending, I use this motion to have the child support held in the registry of the court until a final order disestablishing paternity is entered which could save the client thousands of dollars.
Verified Motion for an Order for Service by Publication
VERIFIED MOTION FOR AN ORDER FOR SERVICE BY PUBLICATION
Brief in Support of Defendant Motion to Dismiss & Motion for More Definite Statement
Motion to dismiss in a lien case and breach of contract case that was filed by contractor to get paid for alleged work performed.
Subject Matter Jurisdiction Brief
Interpleader case where determination was to be made as to who was entitled to life insurance proceeds. Once insurance deposited funds to registry of court they were allowed to withdraw from case and there was no longer an issue of diversity for jurisdiction so court required brief as to why jurisdiction and venue was proper in federal court. Used in Colorado US Federal District court but may be used in all federal courts
Motion to Avoid Judicial Lien
THE DEBTOR, by and through counsel Martinez, Law Firm, LLC, moves this court to avoid judicial lien by stating as follows:
1. Debtor commenced this case on October 19, 2011 by filing a voluntary petition for relief under Chapter 7 of Title 11 of the United States Code.
2. The debtor owns real property occupied as his home located at 5943 S. Tempe Way, Aurora, CO 80015, Arapahoe County Colorado. The debtor believes that the value of the homestead is $224,000 as stated in his schedules.
3. Pursuant to 28 USC 1334, this court has jurisdiction over this motion filed under 11 USC 522(f) to avoid and cancel three judicial liens, to wit:
Motion to Dismiss for Lack of Jurisdiction
COMES NOW, Martinez Law Firm, LLC, behalf of Defendant, Marisa Aranda, and hereby submits this Motion to Dismiss for Lack of Jurisdiction by stating as follows:
1. On January 5, 2015, Defendant, Marisa Aranda was issued a Uniform Summons and Complaint or Penalty Assessment alleging driving under the influence, DUI per se, failure to present insurance and failure to obey a traffic signal. See attached Exhibit 1. In the Summons the officer states the offenses as alleged occurred in Arapahoe County, CO. The Colorado State Patrol Case Report also states the alleged offenses occurred in Arapahoe County, See attached Exhibit 2.
Entry of Appearance, Motion for Discovery, Waiver of Arraignment, Request for Pre-trial Conference
COMES NOW, Martinez Law Firm, LLC, who enters their appearance on behalf of Defendant, Marisa Aranda, and hereby waives arraignment/first appearance set for March 11, 2015, requests a pretrial conference with the Arapahoe County District Attorney at a mutually agreeable time, and requests an Order directing the prosecuting attorney to immediately provide discovery of the following material relevant to this case: