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Defendant’s Motion for County to Pay for Statement of Facts
DEFENDANT’S MOTION FOR _______________ COUNTY TO PAY FOR STATEMENT OF FACTS
Residential Lease Agreement-Landlord and Tenant
My Standard Residential Lease Agreement. Editable if some provisions need to be changed (lawn care, what utilities are or are not paid, etc.). Applicable to Colorado Law Only.
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.
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 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 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.
Motion for Absentee Testimony – Landlord Tenant
Motion seeking to allow testimony via telephone for out of state witnesses/litigants.
Motion For Damages – Post Lawsuit
Motion for damages after winning the lawsuit
Complaint for Discrimination
Compliant under Title VII gender discrimination and SECOND CAUSE OF ACTION FOR VIOLATIONS OF THE NEW YORK STATE HUMAN RIGHTS LAW FOR GENDER DISCRIMINATION AND SEXUAL ORIENTATION DISCRIMINATION
Complaint to Affirm Arbritation
Petition to confirm arbitration award
Complaint for Libel and Slander – New York
Complaint filed in federal court based on diversity for libel and slander
Complaint For Injury
complaint the Federal Employers’ Liability Act, Chapter 2, 45 USC § 51
Complaint for Premise Liability – Personal Injury
Complaint against store for injuries when plaintiff was hit by a cart
Complaint for Tax Refund
Complaint filed against federal government for not refunding tax
Since 2007, a tax preparer will be liable for errors committed on any return. This is because the Internal Revenue Code (IRC) §6694 was modified–broadened, really–replacing “an income tax return preparer” with “a tax return preparer.”
If the appeals officer agrees with the IRS, you have the option of challenging the IRS in court. If you choose to pursue the issue in court, you can pay the amount of tax in dispute and file the appropriate documentation in a U.S. District Court or the Court of Federal Claims for a refund.
To report a tax return preparer for improper tax preparation practices, complete and send Form 14157, Complaint: Tax Return Preparer (PDF) with all supporting documentation to the IRS. The form and documentation can be faxed or mailed, but please do not do both.
Report abusive tax preparers to the IRS.
If you suspect a return preparer filed or changed the return without your consent, you should also file Form 14157-A, Return Preparer Fraud or Misconduct Affidavit. You can get these forms at IRS.gov or by calling 800-TAX-FORM (800-829-3676).