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Plaintiff Objection to Motion in Limine – Insurance Law
Plaintiff response to motion to include insurance name in voir dire
Defandant’s Motion to Intervene – Construction Law
CONCRETE CORP’S MOTION TO INTERVENE in mechanics lien
Motion to Schedule ADR Without Participation of Petitioner
MOTION TO SCHEDULE ADR WITHOUT THE PARTICIPATION OF PETITIONER
Motion for Sanctions for Failure to Provide Discovery
Motion for Sanctions under discovery rules (Rule 16 in Colorado), for prosecution’s repeated failure to provide specific police reports as required. The case settled prior to litigating this issue, though the plea agreement was much better than it could have been largely because of this issue.
Notice of Alibi
Required Notice of Alibi under the Colorado Rules of Criminal Procedure.
Motion for Relief From Judgment Pursuant to Fla. R. Civ. P. 1.540
Motion for Relief From Judgment Pursuant to Fla. R. Civ. P. 1.540
Motion for Declaratory Judgment Regarding Validity of Pre-Nuptial Agreement
Motion for Declaratory Judgment Regarding Validity of Pre-Nuptial Agreement
Final Judgment of Dissolution of Marriage with kids
Final Judgment of Dissolution of Marriage with kids
Motion for Extension of Time to Complete Service of Process and Proposed Order
Motion for Extension of Time to Complete Service of Process and Proposed Order
Unopposed Motion to Appear by Telephone and Proposed Order-Marriage and Divorce
Unopposed Motion to Appear by Telephone and Proposed Order-Marriage and Divorce
Motion for Judicial Default-Marriage and Divorce
Motion for Judicial Default-Marriage and Divorce
Motion to Freeze Assets
Asset freezing is a legal process which prevents a defendant whether innocent or guilty (usually an apparent fraudster) to an action from dissipating their assets from beyond the jurisdiction of a court so as to frustrate a potential judgment. In a divorce, a court can freeze bank accounts and other marital assets.
Motion for Inventory of Business and Accounting of Liquidation Proceeds-Marriage and Divorce
I used this motion to compel an inventory of business assets, accounting of the liquidation proceeds and to have the proceeds held pending an agreement or court order.