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PLAINTIFFS’ REPLY IN SUPPORT OF MOTION TO AMEND COMPLAINT TO INCLUDE A PRAYER FOR EXEMPLARY DAMAGES
PLAINTIFFS’ REPLY IN SUPPORT OF MOTION TO AMEND COMPLAINT TO INCLUDE A PRAYER FOR EXEMPLARY DAMAGES |
PLAINTIFFS’ RESPONSE TO DEFENDANT’S FIFTH MOTION IN LIMINE REGARDING MILLER VALUATIONS
PLAINTIFFS’ RESPONSE TO DEFENDANT’S FIFTH MOTION IN LIMINE REGARDING MILLER VALUATIONS. |
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S FIRST MOTION IN LIMINE REGARDING HYPOTHETICAL SETTLEMENT SCENARIOS
Plaintiff’s response in opposition to defendant’s first motion in limine regarding hypothetical settlement scenarios.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
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S SECOND MOTION IN LIMINE REGARDING PEV AND RESERVE INFORMATION
 PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S SECOND MOTION IN LIMINE REGARDING PEV AND RESERVE INFORMATION. |
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 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
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
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
Independent Contractor Consulting Agreement
Drafted for a client who was hiring an independent contract for consulting work on a political campaign. Can be changed to work as an independent contractor on different types of work. Includes indemnify clause, non disclosure and liability insurance.
Subcontracting Agreement
A subcontracting agreement used for general contractors that need to hire a sub contractor to do work on a project. The agreement written by an attorney with 25 years experience can be used in many different contractual agreements. Perfect for the contractor that wants some protection while hiring additional workforce or contractors
Motion for Clerk to Enter Default
we filed a lawsuit for breach of contract and civil theft. The Defendants failed to answer the complaint. first step is to file a Motion for the Clerk to enter Default once the clerk enters default next would be to file a Motion for Default judgment
Motion for Entry of Default Judgment
Second part of entering a default judgment is the request for the actual judgment. first file a motion for default by the clerk. then file the motion for Default judgment, request the exact damages and include specific language as required by statute.Â