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Plaintiff’s Proposed Jury Instructions on Insurance Collateral
PLAINTIFF’S PROPOSED JURY INSTRUCTION ON INSURANCE Collateral source
Motion to Vacate Bench Warrant
MOTION TO VACATE BENCH WARRANT for a civil show cause order
Motions-Sufficiency of Preliminary Hearing Wisconsin
Motions-Sufficiency of Preliminary Hearing Wisconsin
Motion for Preliminary Ruling on Admissibility of Victim’s Past
MOTION FOR PRELIMINARY RULING ON ADMISSIBILITY OF EVIDENCE OF THE VICTIM’S VIOLENT CHARACTER
Motion for Exoneration by Surety
MOTION FOR EXONERATION
COME NOW the Sureties, by and through their attorney, hereby
Move this honorable court to enter an order of exoneration herein, as grounds therefore, state as follows:
1. That the Defendant herein failed to appear on or about Marc _, 2016 on the bond Posted Feburary _, 2016 in the amount of $3,000.00; the statutory stay of execution expires July _ 2016.
2. That the Defendant is currently in custody in the Pueblo County Jail with various other warrant and bonds (attached as Exhibit A
3. That pursuant to C.R.C 16-4-114(5)(b)(V)(B) and (C) the Sureties are entitled to exoneration as they have shown that the Defendant is in custody in another jurisdiction within the state within 91 days after entry of judgment. WHEREFORE, the Sureties prays this Honorable court grant their Motion for Exoneration.
Motion in Limine to Exclude Damages Evidence from Trial
DEFENDANT’S MOTION IN LIMINE TO EXCLUDE DAMAGES EVIDENCE FROM TRIAL
Agreement for Legal Services
A quasi agreement of flat fee and contingent. I use in complex cases to make sure I get some of my fees covered even if there is no judgment
Defendant’s Motion for Summary Judgment Pursuant to C.R.C.P. Rule 56(b)
DEFENDANT’S MOTION FOR SUMMARY JUDGMENT PURSUANT TO C.R.C.P. RULE 56(b) Plaintiff has Suffered no Damages
Motion in Limine to Exclude Evidence
By failing to object to the timeline stated in the agreed to presumptive Case Management Order, Plaintiff is barred from introducing any evidence or calling any witnesses not disclosed prior to the October 19, 2008 discovery cut-off date
Defendant’s Designation for Non Parties at Fault
DEFENDANT’S DESIGNATION OF NON-PARTIES AT FAULT
Defendant’s First Set of Discovery Requests – Personal Injury
DEFENDANT’S FIRST SET OF DISCOVERY REQUESTS TO PERSONAL INJURY CASE
Affidavit of Attorney’s Fees & Costs on Motion to Compel
AFFIDAVIT OF ATTORNEY’S FEES AND COSTS on motion to compel