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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.
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.
PLAINTIFFS’ MOTION TO AMEND COMPLAINT TO INCLUDE A PRAYER FOR EXEMPLARY DAMAGES
Plaintiff’s motion that requests that the court enter an order permitting them to amend their complaint to include a prayer for exemplary damages.
PLAINTIFFS’ MOTION IN LIMINE RE: DEFENDANT’S “OPPORTUNITY TO SETTLE”
Plaintiff’s motion in limine Re: Defendant’s “opportunity to settle”
PLAINTIFFS’ MOTION FOR LEAVE TO FILE RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION TO BIFURCATE TRIAL OF LIABILITY AND DAMAGES ISSUES OUT OF TIME
Plaintiff’s motion for leave to file response in opposition to defendant’s motion to bifurcate trial of liability and damages issues out of time.
PLAINTIFFS’ MOTION FOR LEAVE TO FILE COMBINED RESPONSE TO DEFENDANT’S RULE 56 MOTIONS OUT OF TIME
Plaintiff’s motion to request that the court permit them to file their combined response to defendant’s rule 56 motions out of time.
PLAINTIFF’S FINAL MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT
Plaintiff requests that the court gran an extension of time to file their response to defendant’s motion for summary judgment.
PLAINTIFFS’ ADDITIONAL MOTION FOR ONE-DAY EXTENSION OF TIME
Plaintiff’s additional motion for one-day extension of time to file responses to defendant’s motion for summary judgement, motion for determination of law and motion for partial summary judgment as to the conduct of expert.
MOTION TO BIFURCATE TRIAL OF LIABILITY AND DAMAGES ISSUES
Defendant’s motion to move pursuant to C.R.C.P 42 to bifurcate the trial of liability issues from the trial of damages issues.
DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME FOR SUBMISSION OF REPLY IN SUPPORT OF MOTION FOR CLARIFICATION
Defendant’s unopposed motion for extension of time to provide a reply in support of motion for clarification.