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Complaint for Fair Labor Standard Act – Ohio
1. the Fair Labor Standards Act (“FLSA”), 29 U.S.C. §201, et seq., the Ohio Minimum Fair Wage Standards Act, O.R.C. Chapter 4111 (“the Ohio Wage Act”), the Ohio Prompt Pay Act, O.R.C. § 4113.15 (“OPPA”), and 28 U.S.C. §1331.
Complaint for Injunctive Relief & Damages Discrimination
RETALIATORY DISCHARGE IN VIOLATION OF THE FAMILY AND MEDICAL LEAVE ACT, WRONGFUL TERMINATION BASED ON DISABILITY DISCRIMINATION, FAILURE TO PROVIDE REASONABLE ACCOMMODATION
Defendant Motion in Limine Excluding EEOC Findings
Defendant Motion in Limine excluding EEOC findings
Defendant Response to motion in Limine for Untimely File
Response to Motion in Limine for untimely filed
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
Complaint for Gender Discrimination
Complaint for Gender Discrimination
Civil Rights Complaint – Sex Discrimination & Retaliation
Complaint for Disability Discrimination, Sex Discrimination, Retaliation
Breach of Contract Complaint – Ohio
Complaint for Breach of Contract, breach of implied dealing, money had and conversion
Motion to Release Funds Held in Court Registry
MOTION TO RELEASE FUNDS HELD IN COURT REGISTRY
Defendants Motion Pursuant to C.R.C.P. 60(b) to Reconsider Order and Certificate of Conferral with C.R.C.P. 121’1-15(8)
DEFENDANTS MOTION PURSUANT TO C.R.C.P. 60(b) TO RECONSIDER ORDER RE: INTEREST RATE ON PROMISSORY NOTE AND CERTIFICATE OF CONFERRAL WITH C.R.C.P. 121 ‘ 1-15(8)
Plaintiff Trial Brief
Plaintiff Trial Brief on premise claim with insect removal
Plaintiff’s Brief Regarding Interest Rate on Promissory Note
PLAINTIFFS’ BRIEF REGARDING INTEREST RATE ON PROMISSORY NOTE
Plaintiff’s Response to Defendant’s Motion in Limine
PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION IN LIMINE TO PRECLUDE EVIDENCE OR ARGUMENT REGARDING TRAFFIC CITATIONS, DRIVING RECORDS AND PRIOR UNRELATED TRAFFIC OFFENSES/CHARGES