Complex Motions
This is a selection from Zara’s hundreds of motion briefs. Names, dates, and other identifying details have been changed to protect privacy. Some covers have been removed for ease of reading.
UPDATES PENDING…
New York Eastern District, Motion for a New Trial. After a trial in a personal injury action.
New York Eastern District, Opposition to Motion for Summary Judgment. In a trip and fall case.
New York Southern District, Bankruptcy Court, Opposition to Trustee’s Motion. In this opposition, we opposed the Trustee’s motion to reopen a Chapter 7 case.
United States Supreme Court, Petition for Review. In a False Claims Act case.
District of Columbia Circuit Court, Petition for Leave to Appeal. After an emergency order was entered in a Federal Aviation Administration proceeding.
New York Appellate Division, First Department, Motion To Reargue and For Leave to Appeal.
New York Supreme Court, Opposition to Plaintiff’s Motion to Reargue and Stay Pending Appeal. Plaintiff lost his summary judgment motion on his claim to quiet title based on an allegedly forged deed. But he failed to meet the standard for reargument or a stay.
New York Surrogate’s Court, Petition to Vacate Surrogate Court Sua Sponte Order Removing Executor. The Surrogate sua sponte suspended testamentary letters and appointed a Public Administrator. This petition sought to undo the damage.
New York Supreme Court, Opposition to Defendant’s Motion for Summary Judgment.
New York Supreme Court, Motion to Compel Discovery. This motion demands discovery responses from a plaintiff bank in a foreclosure case.
New Jersey Appellate Division, Motion for Leave to Appeal.
California Court of Appeals, Motion for Judicial Notice of Additional Documents.
California Superior Court, Opposition to Demurrer.
Florida Fifth Judicial Circuit Court, Opposition to Motion to Dismiss. This brief addresses personal jurisdiction under Florida’s long-arm statute.
New York Research Memo on Motions to Change Venue. The client wanted to know how best to oppose a motion to change venue filed by defendants after plaintiff selected venue in New York County.