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Defendant’s Response to Plaintiff’s Post-Trial Motion to Exceed the $1,000,000.00 Cap
DEFENDANT’S RESPONSE TO PLAINTIFF’S POST-TRIAL MOTION TO EXCEED THE $1,000,000.00 CAP CONTAINED IN C.R.S. § 13-64-302(1)(b)
Order Determining Total Incapacity-Guardianship
Order Determining Total Incapacity-Guardianship
Procedural Objection to Defendant’s Motion – Missed Deadline
PROCEDURAL OBJECTION TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT MISSED DEADLINE
Plaintiff’s Objection to Computer Expert & Request for Shrek Hearing
PLAINTIFF’S OBJECTION TO DEFENSE COMPUTER “EXPERT” REQUEST FOR SHREK HEARING
Defendant Objection to an Ends of Justice Continuance
DEFENDANT OBJECTION TO AN ENDS OF JUSTICE CONTINUANCE
DEFENDANT’S WRITTEN OBJECTION TO ADMISSIBILITY OF EXTRANEOUS OFFENSES, REQUEST FOR PROCEDURAL DETERMINATION BY TRIAL COURT WITH FINDINGS OF FACTS AND CONCLUSIONS OF LAW AND FOR LIMITING INSTRUCTION
DEFENDANT’S WRITTEN OBJECTION TO ADMISSIBILITY OF EXTRANEOUS OFFENSES, REQUEST FOR PROCEDURAL DETERMINATION BY TRIAL COURT WITH FINDINGS OF FACTS AND CONCLUSIONS OF LAW AND FOR LIMITING INSTRUCTION
Motion for Attorney’s Fees Pursuant-Landlord and Tenant
A Motion for an award of attorney’s fees in a civil FED case. Filed under 13-17-101 CRS, seeking the award for a substantially frivolous, groundless, and/or vexatious action and/or pleading. Fact specific, but a good starting point in any request for fees. It was ultimately denied as the defendant “was not aware of the possibility of an award of attorney’s fees” under 13-17-102(6), despite having had several discussions about exactly that on the record.
Motion to Compel Attendance of Out of State Witness
A Motion, filed by the prosecution, asking court certification to compel attendance by an out of state witness.
Workers Comp Motion for Leave to File Amended Response Brief
MOTION FOR LEAVE TO FILE AMENDED RESPONSE BRIEF
Defendant Rule 16 Disclosure Including Alternate Suspect
Defendant charged with Sex Assault on Child. Filed disclosures with alternate suspect defense
Motion to Enforce Settlement Agreement-Civil
Motion to Enforce Settlement Agreement in civil money case.
Plaintiff’s Motion to Strike Testimony
Plaintiff’s Motion to Strike Testimony
Response Brief to Motion for Summary Judgment
Insurance interpleader case where there was a dispute as to who gets a life insurance policy. I represented the name beneficiary and the other party was the descendants two daughters. The daughters claimed they were entitled to insurance proceeds because he was required to pay child support. This my response to their motion for summary judgment.
Complaint for Fair Labor Standard Act
Complaint under the fair labor standard act for failure to pay overtime and retaliation