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Final Judgment by Default and Reservation of Issues
This is a sample Final Judgment by Default awarding alimony, life insurance and attorney’s fees with reservation of issue of how much of each is to be awarded.
Defendant’s Motion In Limmne to Exclude Any & All Evidence That Was Not Properly Disclosed
Civil case where opposing party did not properly disclose witnesses and exhibits prior to jury trial.
Motion to Hold Child Support and Health Insurance Payments in the Registry of the Court
Since the court cannot suspend the child support while the Petition to Disestablish Paternity is pending, I use this motion to have the child support held in the registry of the court until a final order disestablishing paternity is entered which could save the client thousands of dollars.
Affidavit in Support of Petition to Disestablish Paternity
This is an affidavit to be signed by the client in support of their Petition to Disestablish Paternity.
Unopposed Motion for Extension of Time to Complete Defendant’s Disclosure
UNOPPOSED MOTION FOR EXTENSION OF TIME TO COMPLETE DEFENDANTS’ C.R.C.P. 26(a)(2) DISCLOSURE AND CERTIFICATE OF COMPLIANCE WITH C.R.C.P. 121 (c) §1-11 AND 1-12(5)
Respondent – Appellee’s Answer Brief
A Denver hearing Board appeal where we won the Career Service Board Hearing regarding my client discipline. Discipline was overturned and City appealed
Entry of Apprearance & Motion for Leave of the Court to File Answer & Cross-claim
Represented a name defendant
Verified Motion for an Order for Service by Publication
VERIFIED MOTION FOR AN ORDER FOR SERVICE BY PUBLICATION
Motion for State Witnesses to Discuss Facts with Defense Counsel
MOTION FOR AUTHORIZATION FOR STATE’S WITNESSES TO DISCUSS FACTS OF THE CASE WITH DEFENSE COUNSEL
Parenting Time & Joint Custody Parenting Schedule
A sample of different 50/50 parenting schedule
Simplified Answer and Counter claim on renters deposit–Landlord and Tenant
Clients were renting a home and landlord filed lawsuit for back rent and money owed. This simplified answer was used to answer the lawsuit and to counterclaim with Unjust Enrichment and Wrongful Witholding of Earnest Money
Response Brief to Motion for Summary Judgment
Insurance interpleader case where there was a dispute as to who gets a life insurance policy. I represented the name beneficiary and the other party was the descendants two daughters. The daughters claimed they were entitled to insurance proceeds because he was required to pay child support. This my response to their motion for summary judgment.