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Final Judgment by Default and Reservation of Issues
This is a sample Final Judgment by Default awarding alimony, life insurance and attorney’s fees with reservation of issue of how much of each is to be awarded.
Defendant’s Motion In Limmne to Exclude Any & All Evidence That Was Not Properly Disclosed
Civil case where opposing party did not properly disclose witnesses and exhibits prior to jury trial.
Motion for Scientific Paternity Testing
Motion used to compel paternity testing to show he is or is not the biological father.
Motion to Hold Child Support and Health Insurance Payments in the Registry of the Court
Since the court cannot suspend the child support while the Petition to Disestablish Paternity is pending, I use this motion to have the child support held in the registry of the court until a final order disestablishing paternity is entered which could save the client thousands of dollars.
Affidavit in Support of Petition to Disestablish Paternity
This is an affidavit to be signed by the client in support of their Petition to Disestablish Paternity.
Petition to Disestablish Paternity
Florida allows a man to disestablish paternity under certain limited circumstances. This is a petition I have used to successfully disestablish paternity.
Unopposed Motion for Extension of Time to Complete Defendant’s Disclosure
UNOPPOSED MOTION FOR EXTENSION OF TIME TO COMPLETE DEFENDANTS’ C.R.C.P. 26(a)(2) DISCLOSURE AND CERTIFICATE OF COMPLIANCE WITH C.R.C.P. 121 (c) §1-11 AND 1-12(5)
Respondent – Appellee’s Answer Brief
A Denver hearing Board appeal where we won the Career Service Board Hearing regarding my client discipline. Discipline was overturned and City appealed
Entry of Apprearance & Motion for Leave of the Court to File Answer & Cross-claim
Represented a name defendant
Entry of Appearance & Motion To Continue Preliminary Hearing Set
A standard entry of appearance and motion to continue a preliminary hearing due to the attorney not being available for the hearing.
Plaintiff Response To Defendants City Motion for Summary Judgement in Title VII Case
Plaintiff response to summary judgment on a discrimination case against a city employer
Verified Motion for an Order for Service by Publication
VERIFIED MOTION FOR AN ORDER FOR SERVICE BY PUBLICATION
Motion for State Witnesses to Discuss Facts with Defense Counsel
MOTION FOR AUTHORIZATION FOR STATE’S WITNESSES TO DISCUSS FACTS OF THE CASE WITH DEFENSE COUNSEL