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.
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.