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Motion for Contempt in Divorce Proceedings
Motion for contempt for failure to follow court order on divorce, with show cause order and alias summons
Motion to Dismiss Civil Conspiracy Claim
A motion to dismiss a civil conspiracy claim
Motion for Default
Rule 55 Motion for Default. Plaintiff filed lawsuit and Defendant failed to answer. After this motion was filed the court granted a default.
Ex-Parte Motion to Find Defendant
A motion to find Defendant indigent for purpose of state paid investigator
Motion for Contempt Family Law
Filing a Motion for Contempt might cause the other party to file a motion to change the court order. After a divorce decree was entered, one party failed to follow the court order, a contempt was filed and an alias summons was also issued. In family law, a finding of contempt is a way for the Court to enforce child support, spousal support, custody and visitation orders that a party has violated.
Verified Motion to Enforce Parenting Time
Verified Motion to Enforce Parenting Time
Motion to Quash Service Pursuant–Landlord and Tenant
A Motion to Quash Service in a FED (Eviction) case, where Plaintiff failed to follow Rule 304 regarding proper service of a Complaint and Summons. While it may seem so, the Defendants were not married, nor were they otherwise related. As the Rule requires service in this instance separately on each, even had Plaintiff properly served one tenant, he did not properly serve the other.
Ex Parte Motion for Funds for Expert Assistance
An ex parte motion to ask federal district court for payment of defendants expert witness fee.
Ex Parte Motion – Funds for Investigative Assistance
A motion for court payment of investigator
Joint Stipulated Motion to Vacate Final Pretrial Conference
JOINT STIPULATED MOTION TO VACATE FINAL PRETRIAL CONFERENCE OR, IN THE ALTERNATIVE, FOR APPEARANCE BY TELEPHONE
Motion to Preclude Use of the Term Victim
Somewhat standard Motion to precude referring to the accuser/complaining witness as “victim” at trial. Added language includes preclusion of using the term “defendant” in reference to the defendant at trial.
Motion for Abduction Prevention Measures
Motion for Abduction Prevention Measures, which included a restriction of Parenting Time. What’s not in the motion is Crazy Mom’s constant assertion the court and I were engaged in ex-parte communications in an attempt to deprive her of her rights to due process and the fact she filed a Federal Notice of Removal instead of answering the motion (denied, of course, with an admonishment from the Federal judge that she is required to abide by Rule 11). As always, these are fact specific, but this one worked (especially as Crazy Mom failed to appear at the hearing, or otherwise respond to the motion in any way).
Motion to Dismiss FED Case-Landlord and Tenant
Motion to Dismiss a FED case for lack of proper service and improper pleading. Ultimately, it worked, but the court still required a hearing.
Motion for Deposition (Criminal)
A Motion under CRCP 15 for a deposition of an invaluable witness to preserve testimony. As can be seen, the alibi witness was elderly and in very poor health, so we needed to preserve her testimony. Did not actually get to that point as the DA made a very favorable offer, which was accepted, after this motion was filed.