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Reply to the Response for Class Action
A Reply from Plaintiff after they filed a Motion To Certify the Case as Class Action. Defendant filed response
Defense Counsel Closing Statements in Sex Assault – SVU Case
For defense counsel, closing argument is the last chance to remind the jury of the prosecution’s high burden of proof and to persuade the jury that there is, at a minimum, reasonable doubt as to the defendant’s guilt.Client was facing 5 counts of sexual assault by two different children. The trial was a three weeks trial. Prosecution had five experts and 9 witnesses. The jury deliberated for 3.5 days and ended with a hung jury. According to a juror they were locked at 10-2 not guilty.
Motion to Quash Service Pursuant–Landlord and Tenant
A Motion to Quash Service in a FED (Eviction) case, where Plaintiff failed to follow Rule 304 regarding proper service of a Complaint and Summons. While it may seem so, the Defendants were not married, nor were they otherwise related. As the Rule requires service in this instance separately on each, even had Plaintiff properly served one tenant, he did not properly serve the other.
Auto Accident – Civil Jury Instructions
Auto Accident – Civil Jury Instructions
Brief in Support of Motion for Summary Judgment
BRIEF IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT UNDER FED.R.CIV.P 56(a)
Complaint and Summons For County Court Auto Accident
A simple complaint and summons to begin a county court lawsuit for injuries caused by an auto accident
Verified Motion to Enforce Parenting Time
Verified Motion to Enforce Parenting Time
Motion for Contempt Family Law
Filing a Motion for Contempt might cause the other party to file a motion to change the court order. After a divorce decree was entered, one party failed to follow the court order, a contempt was filed and an alias summons was also issued. In family law, a finding of contempt is a way for the Court to enforce child support, spousal support, custody and visitation orders that a party has violated.
Motion for Disclosure of All Attorney Files & Records
Motion for Disclosure of All Attorney Files & Records
Motion for New Trial or to Amend Judgment
PLAINTIFF CLIENT RESPONSE IN OPPOSITION TO DEFENDANT FED.R.CIV.P. 59 MOTION FOR NEW TRIAL OR TO AMEND JUDGMENT
Motion to Strike Exhibits
PLAINTIFF MOTION TO STRIKE EXHIBITS A – D TO DEFENDANT MOTION TO DISMISS THE AMENDED COMPLAINT
Brief in Support of Renewed Motion for Judgment as a Matter of Law
DEFENDANT BRIEF IN SUPPORT OF ITS RENEWED MOTION FOR JUDGMENT AS A MATTER OF LAW PURSUANT TO FED.R.CIV.P. 50(B)
Plaintiff’s Motion for Leave to Amend Complaint & Add Punitive Damages
Plaintiff’s Motion for Leave to Amend Complaint & Add Punitive Damages
Motion to Lift Stay of Proceedings-Landlord and Tenant
Motion to lift stay of proceedings in a county court eviction/FED case. For use where defendant files for bankruptcy after judgement for possession, but before writ of restitution is executed. Not applicable if defendant filed their bankruptcy properly, with required certification and posted rent payments with bankruptcy clerk. In that case, see my bankruptcy Motion for Relief for Stay.
Personal Injury Juror Questionnaire
A jury Questionnaire used for personal injury auto accident cases. This is not voir dire questions, however they can be used as part of your voir dire. Jury instructions are the set of legal rules governing how jurors should behave when deciding a case, often addressing with whom jurors may discuss the case and how jurors will decide who is guilty.