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Brief Regarding VAWA cancellation – Extreme Cruelty
Brief to Board of Immigration Appeals arguing eligibility for VAWA cancellation based upon extreme cruelty by USC spouse due to his alcoholism.
Motion for Judgment not withstanding the verdict or Motion for New Trial
Judgment was entered against my client. We filed a motion based on the evidence for a new trial or in the alternative a Motion Not Withstanding the Verdict. My client was held liability for Outrageous Conduct and emotion distress
BIA Motion to Reconsider I-130 Revocation
Motion to the Board of Immigration Appeals to reconsider the USCIS revocation of a marriage based Form I-130 Petition for Alien Relative. Legal Argument: Impermissible revocation, proper legal standard for good faith marriage, petitioner’s burden to show bona fide marriage, proper evidentiary standard.
Defendant Jury Instruction
Civil case Jury instruction with Mitigation of damages Defense
PLAINTIFFS’ RESPONSE TO DEFENDANT’S MOTION FOR CLARIFICATION OF ORDER RE: HYPOTHETICAL SETTLEMENT SCENARIOS
PLAINTIFFS’ RESPONSE TO DEFENDANT’S MOTION FOR CLARIFICATION OF ORDER RE: HYPOTHETICAL SETTLEMENT SCENARIOS
PLAINTIFFS’ RESPONSE IN OPPOSITION TO DEFENDANT’S THIRD MOTION IN LIMINE REGARDING RIGHTS VERSUS DUTIES
Plaintiff’s response in opposition to defendant’s third motion in limine regarding rights versus duties.
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S SIXTH MOTION IN LIMINE REGARDING
Plaintiff’s response to defendant’s sixth motion in limine regarding expert.
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S SECOND MOTION IN LIMINE REGARDING PEV AND RESERVE INFORMATION
| PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S SECOND MOTION IN LIMINE REGARDING PEV AND RESERVE INFORMATION. |
PLAINTIFFS’ RESPONSE IN OPPOSITION TO DEFENDANT’S FOURTH MOTION IN LIMINE REGARDING
Plaintiff’s response in opposition to defendant’s fourth motion in limine regarding expert.
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S FIRST MOTION IN LIMINE REGARDING HYPOTHETICAL SETTLEMENT SCENARIOS
Plaintiff’s response in opposition to defendant’s first motion in limine regarding hypothetical settlement scenarios.
PLAINTIFFS’ RESPONSE TO DEFENDANT’S FIFTH MOTION IN LIMINE REGARDING MILLER VALUATIONS
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PLAINTIFFS’ RESPONSE TO DEFENDANT’S FIFTH MOTION IN LIMINE REGARDING MILLER VALUATIONS. |
PLAINTIFFS’ REPLY IN SUPPORT OF MOTION TO AMEND COMPLAINT TO INCLUDE A PRAYER FOR EXEMPLARY DAMAGES
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PLAINTIFFS’ REPLY IN SUPPORT OF MOTION TO AMEND COMPLAINT TO INCLUDE A PRAYER FOR EXEMPLARY DAMAGES |
PLAINTIFFS’ REPLY IN SUPPORT OF MOTION IN LIMINE RE: DEFENDANT’S “OPPORTUNITY TO SETTLE”
Plaintiff’s reply in support of motion in limine RE: defendant’s “opportunity to settle”.
PLAINTIFFS PROPOSED JURY INSTRUCTIONS
Plaintiff’s proposed jury instructions.