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Brief in Support of Defendant Motion to Dismiss & Motion for More Definite Statement
Motion to dismiss in a lien case and breach of contract case that was filed by contractor to get paid for alleged work performed.
Verified Motion for an Order for Service by Publication
VERIFIED MOTION FOR AN ORDER FOR SERVICE BY PUBLICATION
Motion to Hold Child Support and Health Insurance Payments in the Registry of the Court
Since the court cannot suspend the child support while the Petition to Disestablish Paternity is pending, I use this motion to have the child support held in the registry of the court until a final order disestablishing paternity is entered which could save the client thousands of dollars.
Defendant’s Motion In Limmne to Exclude Any & All Evidence That Was Not Properly Disclosed
Civil case where opposing party did not properly disclose witnesses and exhibits prior to jury trial.
Motion for Inventory of Business and Accounting of Liquidation Proceeds-Marriage and Divorce
I used this motion to compel an inventory of business assets, accounting of the liquidation proceeds and to have the proceeds held pending an agreement or court order.
Motion for Extension of Time to Complete Service of Process and Proposed Order
Motion for Extension of Time to Complete Service of Process and Proposed Order
Motion for Declaratory Judgment Regarding Validity of Pre-Nuptial Agreement
Motion for Declaratory Judgment Regarding Validity of Pre-Nuptial Agreement
Motion for Relief From Judgment Pursuant to Fla. R. Civ. P. 1.540
Motion for Relief From Judgment Pursuant to Fla. R. Civ. P. 1.540
Motion for Sanctions for Failure to Provide Discovery
Motion for Sanctions under discovery rules (Rule 16 in Colorado), for prosecution’s repeated failure to provide specific police reports as required. The case settled prior to litigating this issue, though the plea agreement was much better than it could have been largely because of this issue.
Defandant’s Motion to Intervene – Construction Law
CONCRETE CORP’S MOTION TO INTERVENE in mechanics lien
Motion to Stike Defendant’s Name’s Designations of Non-Party At Fault
Motion to Stike Defendant’s Name’s Designations of Non-Party At Fault
Motion to modify parenting time and request for payment of arrears and child support
filed this motion to modify the parenting schedule so parents could have 50/50 parenting every 7 days. Also father owed past arrears and a child support needed to be made.
Motion for Attorney Fees with Attached Affidavit-Marriage and Divorce
Filed a motion for attorney fees in case and in divorce case. Motion was granted
Order Determining Homestead Status of Real Property
As a special kind of asset, it passes automatically to the heir(s) under Florida law; however, the heirs may not have clear title. Without clear title, these heirs are unable to sell the home. Therefore, title companies will require an Order Determining Homestead prior to issuing a title policy.