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Appellant Brief on Whether an Illegal Stop Can Affect a License Revocation
Whether or not the exclusionary rule applies in driver’s license revocation proceedings, the express consent statute does not allow the Department of Revenue to revoke a driver’s license pursuant to section 42-2-126 on the basis of a search that itself is the product of an illegal stop and arrest. In this case we argued that, The court of appeals erred in holding that a driver cannot rely on the exclusionary rule to raise the illegality of initial police contact as a defense in a driver’s license revocation proceeding conducted pursuant to section Colorado Law,
Note statute has changed this since the appeal.
MOTION FOR EXTENSION OF TIME TO SERVE COMPLAINT
MOTION FOR EXTENSION OF TIME TO SERVE COMPLAINT
Defendant’s Emergency Motion for Temporary Release to Attend Funeral
Defendant’s Emergency Motion for Temporary Release to Attend Funeral
Plaintiff’s Response to Defendant’s Motion in Limine RE: Defendant’s Injuries
PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION IN LIMINE RE: DEFENDANT’S INJURIES
MOTION FOR MODIFICATION OF CONDITIONS OF DEFENDANT’S BOND
MOTION FOR MODIFICATION OF CONDITIONS OF DEFENDANT’S BOND
Punitive Damages, Motion for Leave to Amend to Add
Motion to Permit Amending Complaint to Allege Punitive Damages
Petition to Waive Bond of Personal Representative
Petition to Waive Bond of Personal Representative
Wrongful Death Complaint Against the Government
Wrongful death against the government – MISSOURI
Motion for Attorney’s Fees Pursuant-Landlord and Tenant
A Motion for an award of attorney’s fees in a civil FED case. Filed under 13-17-101 CRS, seeking the award for a substantially frivolous, groundless, and/or vexatious action and/or pleading. Fact specific, but a good starting point in any request for fees. It was ultimately denied as the defendant “was not aware of the possibility of an award of attorney’s fees” under 13-17-102(6), despite having had several discussions about exactly that on the record.
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.
Complaint (lawsuit) for Sherman Act/ Antitrust
A Civil Federal lawsuit complaint filed for antitrust violations, violation of the Sherman Act.
Summons in Forcible Entry and Unlawful Detainer-Landlord and Tenant
Form Templates
Will Questionnaire
PDF copy of a Will Questionnaire to use for clients to fill out
Petition to Determine Homestead Status of Real Property – testate
Petition to Determine Homestead Status of Real Property – testate