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American Disabilities Act Complaint – Georgia
Compliant filed in Georgia Northern Federal District Court for ADA and lack of access to business
Complaint to Determine Medicare Lien
Complaint filed to determine proper medicare lien – Missouri
Defendant’s Motion for County to Pay for Statement of Facts
DEFENDANT’S MOTION FOR _______________ COUNTY TO PAY FOR STATEMENT OF FACTS
Residential Lease Agreement-Landlord and Tenant
My Standard Residential Lease Agreement. Editable if some provisions need to be changed (lawn care, what utilities are or are not paid, etc.). Applicable to Colorado Law Only.
Motion for Deposition (Criminal)
A Motion under CRCP 15 for a deposition of an invaluable witness to preserve testimony. As can be seen, the alibi witness was elderly and in very poor health, so we needed to preserve her testimony. Did not actually get to that point as the DA made a very favorable offer, which was accepted, after this motion was filed.
Motion to Dismiss FED Case-Landlord and Tenant
Motion to Dismiss a FED case for lack of proper service and improper pleading. Ultimately, it worked, but the court still required a hearing.
Motion for Abduction Prevention Measures
Motion for Abduction Prevention Measures, which included a restriction of Parenting Time. What’s not in the motion is Crazy Mom’s constant assertion the court and I were engaged in ex-parte communications in an attempt to deprive her of her rights to due process and the fact she filed a Federal Notice of Removal instead of answering the motion (denied, of course, with an admonishment from the Federal judge that she is required to abide by Rule 11). As always, these are fact specific, but this one worked (especially as Crazy Mom failed to appear at the hearing, or otherwise respond to the motion in any way).
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 for Absentee Testimony – Landlord Tenant
Motion seeking to allow testimony via telephone for out of state witnesses/litigants.
Motion For Damages – Post Lawsuit
Motion for damages after winning the lawsuit
Complaint for Discrimination
Compliant under Title VII gender discrimination and SECOND CAUSE OF ACTION FOR VIOLATIONS OF THE NEW YORK STATE HUMAN RIGHTS LAW FOR GENDER DISCRIMINATION AND SEXUAL ORIENTATION DISCRIMINATION
Complaint to Affirm Arbritation
Petition to confirm arbitration award
Complaint for Libel and Slander – New York
Complaint filed in federal court based on diversity for libel and slander
Complaint For Injury
complaint the Federal Employers’ Liability Act, Chapter 2, 45 USC § 51