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Complaint for a Slip and Fall
Used this complaint to file a successful lawsuit against a casino in Colorado. It is a premise liability complaint and a sample draft for a slip and fall
Motion to Modify Parental Responsibilities, Parenting Time and Child Support
Filed this motion when the court ordered the mother to be the primary parent and gave father some parenting time and ordered father to pay child support. However child continued to reside with father and mother had little parenting time. So filed Motion to modify from the time of the voluntary change pursuant to C.R.S 14-10-122 so that child support can also be modified from date of voluntary change.
Statutory Offer of Settlement
Simple draft of an offer of settlement. Whereas the Plaintiff has 14 days to accept or offer goes away. If Plaintiff does not receive a judgment for the offer amount then Defendant will be granted cost and fees.
Unopposed Motion for Leave to Allow Defendant’s Expert
Unopposed Motion for Leave to Allow Defendant’s Expert
Summons issued by counsel no return of service
Summons issued by counsel no return of service
Stipulated Plan Regarding Settlement
Stipulated Plan Regarding Settlement
Response to Defendant’s Motion for Attorneys’ Fees and Bill of Costs
Response to Defendant’s Motion for Attorneys’ Fees and Bill of Costs
Reply in Support of Defendant’s Motion for Summary Judgment
Reply in Support of Defendant’s Motion for Summary Judgment
Plaintiff’s Unopposed Motion to Exceed Page and Word Limit in its Response to Defendant’s Motion for Attorney Fees and Bill of Costs
Plaintiff’s Unopposed Motion to Exceed Page and Word Limit in its Response to Defendant’s Motion for Attorney Fees and Bill of Costs
Plaintiff’s Unopposed Motion for Leave to File Brief in Excess of Ten Pages
Plaintiff’s Unopposed Motion for Leave to File Brief in Excess of Ten Pages
Plaintiff’s Unopposed Motion for Extension of Time to File a Reply in Support of its Motion for Partial Summary Judgment
Plaintiff’s Unopposed Motion for Extension of Time to File a Reply in Support of its Motion for Partial Summary Judgment
Plaintiff’s Response to Defendant’s Motion for Summary Judgment
Plaintiff’s Response to Defendant’s Motion for Summary Judgment
Plaintiff’s Response to Defendant’s Motion for Judgment Notwithstanding the Verdict
Plaintiff’s Response to Defendant’s Motion for Judgment Notwithstanding the Verdict
Plaintiff’s Reply in Support of Partial Motion for Summary Judgment
Plaintiff’s Reply in Support of Partial Motion for Summary Judgment
Plaintiff’s Reply in Support of Motion to Quash Subpoena Duces Tecum to Lifetime Construction, LLC Pursuant to C.R.C.P. 45(c)(3)(A)(i)
Plaintiff’s Reply in Support of Motion to Quash Subpoena Duces Tecum to Lifetime Construction, LLC Pursuant to C.R.C.P. 45(c)(3)(A)(i)