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DEFENDANT’S PRE-TRIAL OBJECTION TO IMPROPER VENUE AND MOTION FOR CHANGE OF VENUE
DEFENDANT’S PRE-TRIAL OBJECTION TO IMPROPER VENUE AND MOTION FOR CHANGE OF VENUE
DEFENSE OBJECTIONS TO GOVERNMENT EXHIBITS
DEFENSE OBJECTIONS TO GOVERNMENT EXHIBITS
Attorney Referral to Doctor, Motion in Limine to Preclude Mention
Motion in Limine to Preclude Mention that Plaintiff was referred to doctor by Attorney
Objections to Presentence Report
Defendant’s objections to a pre-sentence report, primarily based on differences in State vs. Federal Definitions regarding the crime charged. US District Court for the District of Arizona.
Defendant’s Objections to Non-Stipulated Jury Instructions
DEFENDANT’S OBJECTIONS TO PLAINTIFF’S NON-STIPULATED AND COMPETING JURY INSTRUCTIONS AND COMPETING VERDICT FORM for Discrimination
Plaintiff’s Objection and Request for Hearing on Defendant’s Motion for Fees and Bill of Cost
PLAINTIFFS’ OBJECTION AND REQUEST FOR HEARING ON DEFENDANTS’ MOTION FOR FEES AND BILL OF COSTS
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.