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Open Public Record Request Letter
A open letter request to City requesting police activity at a local bar/establishment
Respondent’s Verified Motion to Modify Allocation of Parenting Time
A post decree motion to modify parenting time and child support based on one parent not taking or using his time with one of the children.
PURSUANT TO C.R.S. § 14-10-129  AND MOTION TO MODIFY CHILD SUPPORT PURSUANT TO C.R.S. § 14-10-122 and C.R.S. § 14-10-115
Response to motion to Dismiss
A Response to motion to Dismiss in a Title VII employment discrimination case. Filed in Colorado US District Court
Amended Complaint & Jury Demand
A complaint filed In Colorado Federal District Court claiming discrimination based on race and for retaliation
Defendant Rule 56 Motion For Summary Judgment (with Attached Brief)
Motion for Summary Judgement in Breach of Contract and Mechanics Lien case. Lawsuit filed by Contractor for payment for service performed and lien case.
Brief in Support of Defendant Motion to Dismiss & Motion for More Definite Statement
Motion to dismiss in a lien case and breach of contract case that was filed by contractor to get paid for alleged work performed.
Findings of Fact & Conclusion of Law in a Contract Dispute & Excessive Mechanics Lien
A 14 page finding of facts and conclusion of law. Contractor sued owner for money owed to them for work performed, Owner counter sued for breach of contract and excessive in lien in Colorado.
Plaintiff Response to Defendants City Motion for Summary Judgement
Response to motion for summary judgement in employment discrimination case. Client is a police officer that was passed over for a promotion.
Plaintiff’s Motion for Class Certification Pursuant to FED. R. CIV. P. RULE 23
Motion to Class Certification in Employment Discrimination Lawsuit
Plaintiff’s Respoonse to Defendants’ Rule 12(b)(6) Motion to Dismiss
A Response to a Motion to Dismiss on Class Action Employment Discrimination Case. Lawsuit against city for discrimination against Hispanic police officers
Complaint: Class Action for Civil Rights Violations Under Title VII Discrimination
A 34 page complaint filed against a City for a pattern of practice of discrimination against Police Officer based on race. Failure to promote, hire and disciplined employees in violation of Title VII
Subject Matter Jurisdiction Brief
Interpleader case where determination was to be made as to who was entitled to life insurance proceeds. Once insurance deposited funds to registry of court they were allowed to withdraw from case and there was no longer an issue of diversity for jurisdiction so court required brief as to why jurisdiction and venue was proper in federal court. Used in Colorado US Federal District court but may be used in all federal courts
Entry of Appearance, Motion for Discovery, Waiver of Arraignment, Request for Pre-trial Conference
COMES NOW, Martinez Law Firm, LLC, who enters their appearance on behalf of Defendant, Marisa Aranda, and hereby waives arraignment/first appearance set for March 11, 2015, requests a pretrial conference with the Arapahoe County District Attorney at a mutually agreeable time, and requests an Order directing the prosecuting attorney to immediately provide discovery of the following material relevant to this case:
Motion for Reconsideration on child Support Order and or Abatement
Child Support issue where client was over charged by a court order on child support. We requested reconsideration and credit for support already paid with the proposed order
Complaint to Determine Dischargeability of Debt Persuant to 11 U.S.C. 523(a)
A couple filed a bankruptcy against my client and since my client believed they perpetrated fraud against my client I filed this complaint in federal court to stop the bankruptcy from affecting my clients claims.