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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
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
Parenting Time & Joint Custody Parenting Schedule
A sample of different 50/50 parenting schedule
Simplified Answer and Counter claim on renters deposit–Landlord and Tenant
Clients were renting a home and landlord filed lawsuit for back rent and money owed. This simplified answer was used to answer the lawsuit and to counterclaim with Unjust Enrichment and Wrongful Witholding of Earnest Money
Response Brief to Motion for Summary Judgment
Insurance interpleader case where there was a dispute as to who gets a life insurance policy. I represented the name beneficiary and the other party was the descendants two daughters. The daughters claimed they were entitled to insurance proceeds because he was required to pay child support. This my response to their motion for summary judgment.
Response to Summary Judgment for Excessive Force Complaint (Police)
filed this response to a motion for summary judgment in a federal excessive force claim
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