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.
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
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.
Response to Summary Judgment for Excessive Force Complaint (Police)
filed this response to a motion for summary judgment in a federal excessive force claim
Excessive Force Against Sheriff Department -42 U.S.C. §1983
Complaint filed against a sheriff department for excessive force.
Open Public Record Request Letter
A open letter request to City requesting police activity at a local bar/establishment
Respondent’s Verified Motion to Modify Allocation of Parenting Time
A post decree motion to modify parenting time and child support based on one parent not taking or using his time with one of the children.
PURSUANT TO C.R.S. § 14-10-129  AND MOTION TO MODIFY CHILD SUPPORT PURSUANT TO C.R.S. § 14-10-122 and C.R.S. § 14-10-115
Response to motion to Dismiss
A Response to motion to Dismiss in a Title VII employment discrimination case. Filed in Colorado US District Court
Amended Complaint & Jury Demand
A complaint filed In Colorado Federal District Court claiming discrimination based on race and for retaliation
Defendant Rule 56 Motion For Summary Judgment (with Attached Brief)
Motion for Summary Judgement in Breach of Contract and Mechanics Lien case. Lawsuit filed by Contractor for payment for service performed and lien case.
Brief in Support of Defendant Motion to Dismiss & Motion for More Definite Statement
Motion to dismiss in a lien case and breach of contract case that was filed by contractor to get paid for alleged work performed.
Findings of Fact & Conclusion of Law in a Contract Dispute & Excessive Mechanics Lien
A 14 page finding of facts and conclusion of law. Contractor sued owner for money owed to them for work performed, Owner counter sued for breach of contract and excessive in lien in Colorado.
Plaintiff Response to Defendants City Motion for Summary Judgement
Response to motion for summary judgement in employment discrimination case. Client is a police officer that was passed over for a promotion.
Plaintiff’s Motion for Class Certification Pursuant to FED. R. CIV. P. RULE 23
Motion to Class Certification in Employment Discrimination Lawsuit
Plaintiff’s Respoonse to Defendants’ Rule 12(b)(6) Motion to Dismiss
A Response to a Motion to Dismiss on Class Action Employment Discrimination Case. Lawsuit against city for discrimination against Hispanic police officers
Complaint: Class Action for Civil Rights Violations Under Title VII Discrimination
A 34 page complaint filed against a City for a pattern of practice of discrimination against Police Officer based on race. Failure to promote, hire and disciplined employees in violation of Title VII
Subject Matter Jurisdiction Brief
Interpleader case where determination was to be made as to who was entitled to life insurance proceeds. Once insurance deposited funds to registry of court they were allowed to withdraw from case and there was no longer an issue of diversity for jurisdiction so court required brief as to why jurisdiction and venue was proper in federal court. Used in Colorado US Federal District court but may be used in all federal courts
Complaint (lawsuit) on Behalf of Landlord against former Tenant and Guarantor
Complaint (lawsuit) on behalf of landlord against former tenant and a guarantor who co-signed lease. Filed in County Court in Denver, State of Colorado.