Leonard Martinez
- Colorado, United States (US)
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Motion to Continue Jury Trial Due to COVID
A Motion to Continue Criminal Trial due to Concern over the pandemic. In a case where jury pool is hard to come by, a motion to continue the jury trial until pandemic slows down and the jury pool grows.
Business Management Agreement
Downloadable Business Management & Consulting Agreement
Easy and downloadable business management and consulting agreement template. It is used when entering an agreement for an individual or consultant to manage a business or interest of another. Management agreements should be used more for independent contractors or short-term employees that would set parameters on how the consultant manager should handle some duties.
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Essential Business Letter For Employees To Work During COVID-19
All employees performing basic operations have been instructed to comply with social distancing requirements, and we can assure you that we are executing complete and rigorous protocols in our business, in order to minimize the risk of infection by COVID-19. This letter Request for passage of employees performing essential activities
Form for Motion to remove a protection order
Basic Colorado form to remove a protection order.
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S SECOND MOTION IN LIMINE REGARDING PEV AND RESERVE INFORMATION
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S SECOND MOTION IN LIMINE REGARDING PEV AND RESERVE INFORMATION. |
PLAINTIFFS’ REPLY IN SUPPORT OF MOTION IN LIMINE RE: DEFENDANT’S “OPPORTUNITY TO SETTLE”
Plaintiff’s reply in support of motion in limine RE: defendant’s “opportunity to settle”.
DEFENDANT’S UNOPPOSED REQUEST FOR CLARIFICATION AND RULING
Defendant’s unopposed request for clarification and ruling states that the undersigned counsel conferred with counsel for plaintiff who does not object to the relief requested in the motion.
Defendant’s trial brief
Defendant’s trial brief addresses the direction to the parties on the which will be provided to the jury including whether Soriano is now the law of the case and whether the defendant can challenge the reasonableness of the arbitration award.
DEFENDANT’S REPLY IN SUPPORT OF MOTION FOR CLARIFICATION OF ORDER ON FIRST MOTION IN LIMINE REGARDING HYPOTHETICAL SETTLEMENT SCENARIOS
Defendant submits a reply in support of its motion for clarification of the order on defendant’s first motion regarding hypothetical settlement scenarios.
DEFENDANT’S MOTION FOR CLARIFICATION REGARDING THE COURT’S ORDER ON ITS FIRST MOTION IN LIMINE REGARDING HYPOTHETICAL SETTLEMENT SCENARIOS
Defendant’s motion for clarification regarding the court’s order on defendant’s first motion in limine regarding the hypothetical settlement scenarios.
MOTION FOR ADDITIONAL EXTENSION OF TIME TO FILE OPENING BRIEF
MOTION FOR ADDITIONAL EXTENSION OF TIME TO FILE OPENING BRIEF
Plaintiffs’ Motion in Limine to Preclude Defendant from Referencing Other Specific Mass Casualty Events
Plaintiff’s motion for Defendants, their counsel and their witnesses from making or espousing statements, opinions or arguments at trial concerning, pertaining to or relating to specific other mass casualty events
Plaintiffs’ Motion to Exclude Defendants’ Designated Experts Pursuant to C.R.E. 702
Defendant’s motion for an Order excluding at the trial of this matter the testimony of four purported experts proffered by Defendants
Unopposed Motion for Leave to File First Amended Complaint and Jury Demand
Plaintiff’s unopposed motion for leave to file first amended complaint and jury demand.
Motion to Abate and Modify Child Support
Motion to abate and modify child support
Response to Defendant’s Motion for Attorneys’ Fees and Bill of Costs
Response to Defendant’s Motion for Attorneys’ Fees and Bill of Costs
Plaintiff’s Unopposed Motion to Exceed Page and Word Limit in its Response to Defendant’s Motion for Attorney Fees and Bill of Costs
Plaintiff’s Unopposed Motion to Exceed Page and Word Limit in its Response to Defendant’s Motion for Attorney Fees and Bill of Costs