Criminal Defense Expert

Colorado, United States (US)
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Personal Injury

Plaintiff’s Response to Motion for Summary Judgment

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PLAINTIFF’S RESPONSE TO MOTION FOR SUMMARY JUDGMENT AND MOTION TO ACCEPT PUNITIVE DAMAGES AND OUTRAGEOUS CONDUCT CLAIM

$25.00

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Personal Injury, Ski Accident

Complaint for Negligence Against Ski Area

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The four elements that a plaintiff must prove to win a negligence suit are 1) Duty, 2) Breach, 3) Cause, and 4) Harm. Generally speaking, when someone acts in a careless way and causes an injury to another person, under the legal principle of “negligence” the careless person will be legally liable for any resulting harm. Ski Resort Immunity and Inherent Risk of Skiing protects the ski resort from most claims of negligence – which usually must be proved to win a personal injury lawsuit.

$20.00

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Civil Litigation, Personal Injury

Plaintiff’s Motion for Leave to Amend Complaint to add Punitive Damages Against Defendants and Company

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PLAINTIFF’S MOTION FOR LEAVE TO AMEND COMPLAINT TO ADD PUNITIVE DAMAGES AGAINST DEFENDANTS AND COMPANY

$50.00

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Personal Injury, Ski Accident

Complaint for Premise Liability against Ski Area

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Premise liability claim against Ski Area

$20.00

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Criminal Law

Motion for Deposition (Criminal)

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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.

$40.00

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Civil Litigation, Landlord and Tenant Law

Motion to Dismiss FED Case-Landlord and Tenant

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Motion to Dismiss a FED case for lack of proper service and improper pleading. Ultimately, it worked, but the court still required a hearing.

$40.00

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Child Custody, Divorce and Marriage

Motion for Abduction Prevention Measures

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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).

$40.00

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Landlord and Tenant Law

Motion for Absentee Testimony – Landlord Tenant

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Motion seeking to allow testimony via telephone for out of state witnesses/litigants.

$45.00

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Criminal Law

Motion In Limine for Brief Non-Argumentative Statement Prior to Jury Selection

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Motion seeking to give a brief, non-argumentative, opening statement to a jury panel prior to voire dire. Includes constitutional language as well as direction form Chief Justice Directives on such practices.

$20.00

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Criminal Law

Motion to Compel Attendance of Out of State Witness

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A Motion, filed by the prosecution, asking court certification to compel attendance by an out of state witness.

$35.00

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Criminal Law

Objection to Court Scheduling Order

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A written objection to a pre-trial scheduling Order compelling the defense to disclose witness and exhibit lists well in advance of trial. Includes Rule 16 citations and constitutional arguments against the Order.

$20.00

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Criminal Law

Motion for Discovery of Oral Statements

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A motion attempting to secure the disclosure of certain oral statements made to investigators, allegedly, by both the defendant and the alleged victim. These statements would, if true, be exculpatory in nature.

$50.00

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Criminal Law

Motion to Preclude Use of the Term Victim

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Somewhat standard Motion to precude referring to the accuser/complaining witness as “victim” at trial. Added language includes preclusion of using the term “defendant” in reference to the defendant at trial.

$40.00

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Criminal Law

Motion for a Fair and Impartial Jury

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Motion to specify and/or modify a judge’s standing voire dire procedure to allow for a more fair and impartial jury selection.

$10.00

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Civil Litigation, Personal Injury, Ski Accident

Ski Accident Lawsuit Filed Against Ski Area

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Filed lawsuit against ski area for injuries suffered by a skier

$25.00

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Civil Litigation, Landlord and Tenant Law

Motion to Quash Service Pursuant–Landlord and Tenant

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A Motion to Quash Service in a FED (Eviction) case, where Plaintiff failed to follow Rule 304 regarding proper service of a Complaint and Summons. While it may seem so, the Defendants were not married, nor were they otherwise related. As the Rule requires service in this instance separately on each, even had Plaintiff properly served one tenant, he did not properly serve the other.

$40.00

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