Response to Motion to Vacate a Default Judgment & Motion to Strike Answer
Great response to a Defendant who failed to file an answer and then after judge ordered default, defendant filed a motion to vacate the default and a motion to leave to file an answer.
Motion For Damages – Post Lawsuit
Motion for damages after winning the lawsuit
Motion for Summary Judgment – Auto Injury
MOTION FOR for summary judgment as it relates to the family car doctrine
Motion in Limine to Include Traffic Citation
DEFENDANT _______________ MOTION IN LIMINE RE: EVIDENCE OF TRAFFIC CITATION
Response to Motion Limine
RESPONSE OF DEFENDANT TO DEFENDANTS AND THE ESTATE OF MOTION IN LIMINE TO PRECLUDE THE ADMISSION OF EVIDENCE OF SETTLEMENT WITH PLAINTIFF
Motion for Reconsideration – Child Custody
PETITIONER’S MOTION TO RECONSIDER ORDER DENYING PETITIONER INTEREST FOR CHILD SUPPORT ARREARS
Opening Appeal Brief – Child Custody
Client was owed years of child support and trial court denied her request for interest on the arrears. We filed an appeal on the issue of whether she is entitled to interest
A Colorado Non-Compete Agreement
A Colorado Employer’s non compete agreement
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.
Colorado Lien Notice Disburser
Colorado Mechanic lien notice disburser
Ex Parte Motion – Funds for Investigative Assistance
A motion for court payment of investigator
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.
Brief in Support of Motion for Summary Judgment
BRIEF IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT UNDER FED.R.CIV.P 56(a)
Motion for New Trial or to Amend Judgment
PLAINTIFF CLIENT RESPONSE IN OPPOSITION TO DEFENDANT FED.R.CIV.P. 59 MOTION FOR NEW TRIAL OR TO AMEND JUDGMENT
Motion to Strike Exhibits
PLAINTIFF MOTION TO STRIKE EXHIBITS A – D TO DEFENDANT MOTION TO DISMISS THE AMENDED COMPLAINT
Brief in Support of Renewed Motion for Judgment as a Matter of Law
DEFENDANT BRIEF IN SUPPORT OF ITS RENEWED MOTION FOR JUDGMENT AS A MATTER OF LAW PURSUANT TO FED.R.CIV.P. 50(B)
Ex-Parte Motion to Find Defendant
A motion to find Defendant indigent for purpose of state paid investigator