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Wrongful Death Complaint – Auto Accident
A Wrongful Death complaint for auto accident filed in Federal court based on diversity
Appellant Opening Brief Regarding Courts failure to order Maintenance
Filed an appeal on the issue of Maintenance. I represented a man who made half the amount of his wife. Court refused to grant him Maintenance based on the fact that he had a teaching job.
Stipulated Motion for Extension of Time to Respond to Plaintiff’s Complaint
DEFENDANT DR. —’S STIPULATED MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT
Colorado Lien Notice Disburser
Colorado Mechanic lien notice disburser
Ex Parte Motion – Funds for Investigative Assistance
A motion for court payment of investigator
Motion for the Court to Direct the Court Reporter t take Voir Dire Examination
MOTION FOR THE COURT TO DIRECT THE COURT REPORTER
TO TAKE VOIR DIRE EXAMINATION OF THE JURY AND
ALL FINAL ARGUMENTS IN THE ABOVE STYLED AND NUMBERED CAUSE
Motion In Limine to Preclude Events
MOTION IN LIMINIE TO PRECLUDE EVENTS
Stipulated Motion for Dismissal with Prejudice
STIPULATED MOTION FOR DISMISSAL WITH PREJUDICE
Defendant’s Motion in Limine – Civil Litigation
I. Plaintiffs should be precluded from eliciting opinion testimony from Defendant’s employee, NAME, CNA.
II. Plaintiff should be precluded from referring to “never events.”
III. Plaintiffs should be precluded from making “negligence in the air” arguments.
Motion to Preclude Mention of Uncharged Crimes & Other Inadmissible Evidence
MOTION IN LIMINIE TO PRECLUDE MENTION OF UNCHARGED CRIMES AND OTHER INADMISSIBLE EVIDENCE
Amended Complaint for Premise Liability – Missouri
A lawsuit filed for premise liability, complaint
Answer to Personal Injury Complaint – Georgia
Answer is the first formal response given by the defense to a complaint filed with the court by the plaintiff. This opening written statement will admit or deny the allegations, or demand more information about the claims of wrongdoing.When drafting an answer, one must: (1) follow the local, state, and federal court rules; (2) research the legal claims in the adversary’s complaint; (3) respond to the adversary’s factual allegations; and (4) assert affirmative defenses, counterclaims, cross-claims, or third-party claims, if applicable.
Reply to the Response for Class Action
A Reply from Plaintiff after they filed a Motion To Certify the Case as Class Action. Defendant filed response
Defense Counsel Closing Statements in Sex Assault – SVU Case
For defense counsel, closing argument is the last chance to remind the jury of the prosecution’s high burden of proof and to persuade the jury that there is, at a minimum, reasonable doubt as to the defendant’s guilt.Client was facing 5 counts of sexual assault by two different children. The trial was a three weeks trial. Prosecution had five experts and 9 witnesses. The jury deliberated for 3.5 days and ended with a hung jury. According to a juror they were locked at 10-2 not guilty.