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Plaintiffs Unopposed Motion For Enlargement Of Time To Submit Expert Rebuttal Disclosures, Pursuant To C.R.C.P. Rule 6
A motion to request an extension of time to submit expert’s reports.
Plaintiff’s Motion for Liquidated Damages and Statutory Penalties
A motion for liquidated damages and penalties after a jury finds a defendant guilty of violating the fair standard act.
Order re Motion to Compel Compliance
The courts order on defendant’s motion to compel plaintiff to pay attorney fees.
Order to Show Cause
A motion to compel for a party to follow court order and to produce their expert witness’ file.
MOTION FOR LEAVE TO AMEND FIRST AMENDED COMPLAINT TO ADD A CLAIM FOR EXEMPLARY DAMAGES
A motion for leave to amend a complaint to add a claim for exemplary damages.
MOTION FOR DISCOVERY ON ATTORNEY FEES
A motion for discovery on a request for attorney fees.
Defendants Motion in Limine Related to Limitations Period
A sample motion by defendant limiting testimony for claims made outside the statue of limitations.
Motion Requesting Notice of Prosecution’s Intent to Introduce Alleged Similar Evidence
A sample Motion requesting notice of prosecution’s intent to introduce alleged similar transaction evidence. Well written request for the Court to order the prosecution to specify any instances of alleged prior evidence.
Entry of Appearance and Motion for Preliminary Hearing
A sample of an Entry of Appearance and Motion for Preliminary Hearing. A well written form for an appearance for defendant.
Unopposed Motion to Continue Jury Trial
A sample of an unopposed motion to continue jury trial. A well written unopposed motion by the defense counsel to continue the scheduled jury trial which is without objection from the People.
Motion to Suppress Unconstitutionally Obtained Convictions
Sample of a Motion to suppress unconstitutionally obtained convictions. A well written motion to suppress convictions based on the convictions being obtained without counsel.
Motion in Limine to Preclude the Prosecution’s Proposed Expert Testimony
Sample of a motion to preclude the prosecution’s proposed expert testimony. A well written motion to object against the prosecution’s expert witness’s testimony.
Motion to Suppress Defendants Statement during Custodial Interrogation
Sample to suppress Defendant’s statements while in custody without proper Miranda advisement. Well written motion to exclude evidence from an unlawful interrogation
Motion for 404B Notice
the motion requests that the Court Order the prosecution to provide notice in advance of trial that conforms to the standards set forth in People v. Spoto. Further, if the prosecution seeks to introduce such evidence, the Defendant moves that a hearing on the admissibility of such evidence be held sufficiently in advance of trial in order to afford counsel adequate time to confront the proffered evidence.
MOTION TO SUPPRESS ILLEGAL STOP, INVOLUNTARY ROADSIDE TESTS, WARRANTLESS ARREST, STATEMENTS AND INVOLUNTARY BREATH TEST
MOTION TO SUPPRESS ILLEGAL STOP, INVOLUNTARY ROADSIDE TESTS, WARRANTLESS ARREST, STATEMENTS AND INVOLUNTARY BREATH TEST