#Motion to dismiss sexample how to#
#Motion to dismiss sexample trial#

Boulevard Rule Motion for Judgment in Motor Vehicle Collision.Response to Motion to Dismiss: Defendant sought dismissal claiming the worker’s compensation barred Plaintiff’s claim.Judgment on Whether Defendant Was Manufacturer of a Product: The battle here is whether a hybrid service/product can be subject to a strict liability claim.Plaintiff’s Response to Motion to Dismiss Defunct LLC.Our Reply Motion After Defendant’s Response.Partial Summary Judgment: Seeking summary judgment based on the presumption of negligence in a rear end traffic collision.Motions for Summary Judgment/Motions to Dismiss Defendant’s Motion to Compel Expert Depositions: This defense motion does a pretty good job of laying out the issue from the defense point of view.Opposition to Motion to Compel Expert Depositions: Is there a required order of who goes first when it comes to expert depositions? This is a battle we fought in a medical malpractice case in Baltimore.Defendant’s Motion to Compel Deposition and Protective Order from Fact Witness Deposition.Opposition to Allow Second Expert Deposition.Frey-Reed Motion/Expert Financials: We won this motion, kicking out defendant’s only expert in the case.Prevent Expert from Suggesting Victim is Malingering or Lying.

#Motion to dismiss sexample trial#

Protective Order from Second Trial Deposition.Another Motion to Compel Financials (more recent version).Judge’s Order Granting Release of Expert’s Financial Records.Response to Motion to Protective Order for Expert Financial Records: This is appropriate when the expert refuses to provide the documents that back up her deposition testimony about how much money she makes does medical/legal work.Motion to Extend Discovery Deadline: Sometimes, the case progresses in such a way that you need to extend the discovery deadline to complete the work needed to prepare for trial.This speeds the process along if defense counsel is dragging their feet. Expedited Discovery: With a pending statute of limitations looming, you want to make sure you have all of the appropriate parties in the case.Opposition to Motion to Compel Vocational Rehabilitation Expert Interview: Defense counsel wanted to give the vocational rehabilitation expert a chance to essentially depose the plaintiff again.They can do this with a subpoena, not a blanket HIPAA authorization. Plaintiff’s Response to Motion to Compel Medical Records Authorization: Many defendants want to go around HIPAA and get the records from the medical providers.This motion requests a second deposition at defendant’s expense. Compel Deposition: Defense counsel with increased frequency instructs the defendant not to answer questions, usually because they don’t like the questions.Defendant’s Motion to Compel a Physical Exam (citing IME “handbook”).

Another Response to Motion to Compel Physical Examination.

The battle is usually over the conditions of the exam or the expert’s failure to provide financial information

Response to Motion to Compel a Defense Medical Exam: We generally do not oppose the exam itself.

Normally, the response is just providing the answers.

Compel Discovery Responses: Standard filing to get the other party to answer discovery.

But there are some cases where it is absolutely necessary.

Motion to Recuse Judge: You do not want to file a motion to recuse a judge very often.

Our private investigator found that he did. This was a venue battle over the more specific factual issue of whether defendant was doing business in the jurisdiction in which we brought the claim.

Opposition to Motion to Dismiss for Improper Venue: We have a lot of sample motions about venue because in Maryland, any in many jurisdictions, venue can make a real difference in settlement value.

We won this motion and got a $5.5 million verdict

Our response: This is our latest effort at fine-tuning our forum non conveniens arguments.

Maryland allows for alternative service if certain hoops have been jumped.

Service by Alternative Method: Sometimes, you just can’t track down the defendant.

Consolidate Cases: This is a motion to merge two related causes of action.

Motions Seeking and Opposing Summary Judgment.

#Motion to dismiss sexample how to#

These example motions can be used in whole or in part or may just give you ideas as to what might work for your pleading and how to write them. Sometimes, you have to reinvent the wheel when drafting legal documents but sometimes you do not. Below is a list of sample motions, responses to motions, and a few court orders.