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Consolidated Motion For A Mental Evaluation Of Witness TMR To Assess Testimonial Competency
This document involves the defense of a sex offender case. This particular file is a motion for a mental evaluation of a witness. This is very useful when challenging the validity of witness testimony.
Letter to Client regarding starting Non Profit
A general letter I send out to clients that are thinking of opening a non profit organization. Sample letter to client regarding starting non profits.
Respondent’s Evidence Submission
Respondent’s evidence submission to Immigration Court with Exhibit list, witness list and Certificate of Service
Occupational Safety and Health Admistration Workers Rights Brochure
A brochure put out by OSHA for employees. Employees know your rights.Â
BIA Brief Regarding Lawful Admission
Brief to the Board of Immigration Appeals arguing that a a waive-through at a port of entry constitutes a lawful admission tot he US for purposes of adjustment of status.
Motion to Terminate under Pereira
Motion to Immigration Court moving for termination of proceedings based upon the US Supreme Court decision in Pereira v. Sessions.
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.
Defendant Jury Instruction
Civil case Jury instruction with Mitigation of damages Defense
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 SCENARIOSÂ
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.Â
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.Â
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.Â