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Defendant Rule 16 Disclosure Including Alternate Suspect
Defendant charged with Sex Assault on Child. Filed disclosures with alternate suspect defense
Workers Comp Motion for Leave to File Amended Response Brief
MOTION FOR LEAVE TO FILE AMENDED RESPONSE BRIEF
Motion to Compel Attendance of Out of State Witness
A Motion, filed by the prosecution, asking court certification to compel attendance by an out of state witness.
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.
DEFENDANT’S WRITTEN OBJECTION TO ADMISSIBILITY OF EXTRANEOUS OFFENSES, REQUEST FOR PROCEDURAL DETERMINATION BY TRIAL COURT WITH FINDINGS OF FACTS AND CONCLUSIONS OF LAW AND FOR LIMITING INSTRUCTION
DEFENDANT’S WRITTEN OBJECTION TO ADMISSIBILITY OF EXTRANEOUS OFFENSES, REQUEST FOR PROCEDURAL DETERMINATION BY TRIAL COURT WITH FINDINGS OF FACTS AND CONCLUSIONS OF LAW AND FOR LIMITING INSTRUCTION
Defendant Objection to an Ends of Justice Continuance
DEFENDANT OBJECTION TO AN ENDS OF JUSTICE CONTINUANCE
Plaintiff’s Objection to Computer Expert & Request for Shrek Hearing
PLAINTIFF’S OBJECTION TO DEFENSE COMPUTER “EXPERT” REQUEST FOR SHREK HEARING
Procedural Objection to Defendant’s Motion – Missed Deadline
PROCEDURAL OBJECTION TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT MISSED DEADLINE
Order Determining Total Incapacity-Guardianship
Order Determining Total Incapacity-Guardianship
Defendant’s Response to Plaintiff’s Post-Trial Motion to Exceed the $1,000,000.00 Cap
DEFENDANT’S RESPONSE TO PLAINTIFF’S POST-TRIAL MOTION TO EXCEED THE $1,000,000.00 CAP CONTAINED IN C.R.S. § 13-64-302(1)(b)
Plaintiff’s Objection and Request for Hearing on Defendant’s Motion for Fees and Bill of Cost
PLAINTIFFS’ OBJECTION AND REQUEST FOR HEARING ON DEFENDANTS’ MOTION FOR FEES AND BILL OF COSTS
Defendant’s Objections to Non-Stipulated Jury Instructions
DEFENDANT’S OBJECTIONS TO PLAINTIFF’S NON-STIPULATED AND COMPETING JURY INSTRUCTIONS AND COMPETING VERDICT FORM for Discrimination
Objections to Presentence Report
Defendant’s objections to a pre-sentence report, primarily based on differences in State vs. Federal Definitions regarding the crime charged. US District Court for the District of Arizona.