Leonard Martinez
- Colorado, United States (US)
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Freelance Writer Contract
A contract used for writers or individuals that want to hire a writer for a magazine, book or novel. Sample contract to use to hire a freelance writer. Writers are now going freelance or independent, they need to make sure they are protected. this contract protects both parties.
Wrongful Death Complaint With Res Ispa Loquitor
Complaint filed in District Court in Colorado for a family member that was killed while working when a steel beam fall and hit him in the head. The Complaint includes wrongful death, negligence and Res Ipsa Loquitur : To prove res ipsa loquitor negligence, the plaintiff must prove 3 things: The incident was of a type that does not generally happen without negligence, It was caused by an instrumentality solely in defendant’s control, The plaintiff did not contribute to the cause .Â
Response To motion for Extension of Time to Pay Property Distribution in Divorce
client was owed money from a divorce in property distribution. wife was to pay husband $85,000.00 wife paid some but was requesting more time to pay the additional money. We filed this objection and argued the alternative that my client be granted 8% interest from time of divorce if court does grant her the motion for extension of time to pay the husband
Motion for Entry of Default Judgment
Second part of entering a default judgment is the request for the actual judgment. first file a motion for default by the clerk. then file the motion for Default judgment, request the exact damages and include specific language as required by statute.Â
Motion for Clerk to Enter Default
we filed a lawsuit for breach of contract and civil theft. The Defendants failed to answer the complaint. first step is to file a Motion for the Clerk to enter Default once the clerk enters default next would be to file a Motion for Default judgment
Motion to move forward with default
A motion I filed after I filed a motion to modify decision making and parenting time. Respondent never answered and failed to appear for mediation. So I filed a request for court to enter a default against the Respondent
Satisfaction of Judgment
This satisfaction is filed to the court to show that the attorney fees order by the court has been paid. Party should file this if a judgment has been entered and that judgment has been satisfied with payment
Construction company collection letter
A letter sent to a contractor for work performed on a construction project but has not been paid.
Colorado Court of Appeal Opinion on Family Law Matters
May 16, 2019 Colorado Court of Appeals decision regarding attorney fees in divorce, family law matter under C.R.S 14-10-119. Court vacated attorney fees granted by district court and sent it down on remand.  Court granted fathers appeal in regarding to calculation of income as it relates to his workers compensation lump sum settlement. District court erred when calculating income of workers compensation settlement and divided by twelve months. Case sent back down to District court.
Procedural Rules For Workers Compensation Hearings – Workers Compensation Legal Document
The Divisions of Workers Compensation provide procedural rules for all aspects of the hearing and appeal process.