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This sample opposition to California motion to vacate judgment with an attorney affidavit of fault is used to oppose a motion made under the mandatory attorney affidavit of fault provisions of Code of Civil Procedure section 473(b) on several grounds including that the motion is untimely, does not include the required attorney affidavit of fault, the attorney is covering up for the client and other grounds. The sample on which this preview is based is 12 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority and a sample declaration.
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This sample motion for new trial in United States Bankruptcy Court is filed under the provisions of Federal Rule of Civil Procedure 59(a) and Federal Rule of Bankruptcy Procedure 9023 on several grounds including that (1) the verdict is against the weight of the evidence; (2) newly discovered evidence; (3) prejudicial conduct by the court or opposing counsel, and (4) juror misconduct. The sample on which this preview is based is 16 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service by mail. The author is an entrepreneur and freelance paralegal that has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for sale. Note that the author is NOT an attorney and no guarantee or warranty is provided.
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These sample special interrogatories for California is for a California civil case and is intended to be used by a defendant but can be modified for use by a plaintiff. The sample document on which this preview is based is very detailed and is 33 pages long including the declaration for additional discovery and proof of service by mail.
Sample opposition to motion for judgment notwithstanding the verdict for cal...LegalDocsPro
This sample opposition to motion for judgment notwithstanding the verdict for California is made on the grounds that substantial evidence supports the jury’s verdict. The sample on which this preview is based is 11 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, proposed order and proof of service by mail.
Answer, Counterclaims & Third Party Claims - Non-Compete & Tortious InterferencePollard PLLC
This is one of our cases in Volusia County, Florida. Our clients - all of the defendants in the case - were sued for breach of a non-compete agreement, breach of fiduciary duty and tortious interference.
We responded with counterclaims for a declaratory judgment holding the non-compete agreement(s) unenforceable, third party claims for breach of fiduciary duty and breach of contract and a demand for indemnification.
This is a good example of our level of work. We have extensive experience litigating non-compete and tortious interference cases on both sides. We prosecute and defend these types of cases.
In every case, we have a process: First, we master the facts. Many lawyer and law firms get involved in a case and immediately focus on law. In our view, that is the wrong approach. All cases are driven by facts. Any legal strategy must be tailored to the specific facts of a specific case.
We do not take anything for granted. We do not default to the same tired boilerplate pleadings. In every new case, we fashion a specific strategy for that case.
If you have a non-compete or tortious interference case, just give us a call at 9543-32-2380. That's what we're here for.
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1. 4:08-cv-02753-TLW-TER Date Filed 10/27/09 Entry Number 77 Page 1 of 5
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF SOUTH CAROLINA
FLORENCE DIVISION
HOWARD K. STERN, as Executor of the )
Estate of Vickie Lynn Marshall, )
a/k/a Vickie Lynn Smith, ) Civil Action No. 4:08-cv-2753-TLW
a/k/a Vickie Lynn Hogan, )
a/k/a Anna Nicole Smith, )
)
Plaintiff, )
)
vs. )
)
STANCIL SHELLEY, )
a/k/a Ford Shelley, )
G. BEN THOMPSON, )
and John or Jane Doe 1-12 whose true names )
are unknown, )
)
Defendants. )
/
PLAINTIFF’S MOTION FOR LEAVE
TO AMEND AND SUPPLEMENT COMPLAINT; AND
FOR JOINDER OF ADDITIONAL DEFENDANTS
COMES NOW Plaintiff Howard K. Stern, as Executor of the Estate of Vickie Lynn
Marshall a/k/a Anna Nicole Smith (the “Executor”) and hereby moves this Court for an order
granting leave, pursuant to Federal Rules of Civil Procedure 15(a)(2), 15(d), and 20(a)(2), (i) to
amend and supplement the Complaint filed by the Executor on August 4, 2008, (ii) to join
Gaither Bengene Thompson, II (“Gaither”), Melanie Thompson (“Melanie”), Gina Thompson
Shelley (“Gina”) (collectively, the “Doe Defendants”), and Susan M. Brown (“Brown”) and The
Law Offices of Susan M. Brown, P.C. (the “Law Firm”) as party defendants; and (iii) to amend
the caption of the case accordingly.
Through discovery, the Executor has learned additional facts that support the claims set
forth in the Complaint. For example, the Executor has learned of additional conversions of Estate
1
2. 4:08-cv-02753-TLW-TER Date Filed 10/27/09 Entry Number 77 Page 2 of 5
property, such as Ford Shelley’s distribution of Estate property to Geraldo Rivera and the
California Department of Justice. Moreover, the Executor has learned the true identities of the
Doe Defendants. Accordingly, this Court should grant the Executor leave to amend his
Complaint pursuant to Federal Rule of Civil Procedure 15(a)(2).
The Executor has also learned of additional transactions, occurrences, and events that
have occurred since August 4, 2008, which is the date of the pleading sought to be
supplemented. For example, the Executor has learned that as recently as September 22, 2009,
Brown continued to maintain copies of Estate property on the Law Firm’s computer, which not
only constitutes conversion but is also a violation of the Consent Preliminary Injunction entered
by this Court. Therefore, this Court should grant the Executor leave to amend his Complaint
pursuant to Federal Rule of Civil Procedure 15(d).
Through discovery and only after an order from the United States District Court for the
Northern District of Georgia compelling Brown’s attendance at a deposition, the Executor
learned that Brown and the Law Firm played an integral role in the unauthorized transfer of
Estate property. Furthermore, the Executor learned that Brown herself committed numerous acts
that fall within the claims alleged by the Executor in this action. Accordingly, this Court should
permit the Executor to add Brown and the Law Firm as party defendants pursuant to Federal
Rules of Civil Procedure 15(a)(2) and 20(a)(2).
A copy of the First Amended Complaint is attached hereto as Exhibit “A” and is
incorporated by reference.
The grounds for the Motion are more fully set forth in the accompanying brief, and the
factual bases upon which the amended and supplemental claims are based are set forth in
Exhibit A.
2
3. 4:08-cv-02753-TLW-TER Date Filed 10/27/09 Entry Number 77 Page 3 of 5
WHEREFORE, the Executor respectfully requests that his motion be granted and this
Court enter an order:
(1) granting leave for the Executor to file his amended and supplemented complaint;
(2) granting leave for the Executor to identify and join the Doe Defendants as the
following named parties: Gaither Bengene Thompson, II, Melanie Thompson, and Gina
Thompson;
(3) joining Susan M. Brown and The Law Offices of Susan M. Brown, P.C. as party
defendants; and
(4) amending the caption of this action accordingly.
The Executor further requests that the Defendants be required to file a pleading in
response, if any, not more than ten days after service of the First Amended Complaint.
Respectfully submitted this 27th day of October, 2009.
/s/ Louis Nettles
L. Lin Wood
(Georgia Bar No. 774588) (Pro hac vice)
Lin.Wood@BryanCave.com
Nicole Jennings Wade
(Georgia Bar No. 390922) (Pro hac vice)
Nicole.Wade@BryanCave.com
Luke A. Lantta
(Georgia Bar No. 141407) (Pro hac vice)
Luke.Lantta@BryanCave.com
BRYAN CAVE LLP
One Atlantic Center
Fourteenth Floor
1201 West Peachtree Street, N.W.
Atlanta, Georgia 30309
Telephone: (404) 572-6600
Facsimile: (404) 572-6999
3
4. 4:08-cv-02753-TLW-TER Date Filed 10/27/09 Entry Number 77 Page 4 of 5
Karl A. Folkens
(District Court ID No. 854)
Karl@folkenslaw.com
Louis Nettles
(District Court ID No. 2521)
Louis@folkenslaw.com
FOLKENS LAW FIRM, P.A.
3326 West Palmetto Street
Florence, South Carolina 29501
Telephone: (843) 665-0100
Facsimile: (843) 665-0500
Attorneys for the Executor
CERTIFICATE OF CONFERENCE
Pursuant to Local Rule of Court 7.02, prior to filing this motion, counsel for the
Executor conferred with opposing counsel and attempted in good faith to resolve the matter
contained in this motion.
/s/ L. Lin Wood
L. Lin Wood
(Georgia Bar No. 774588) (Pro hac vice)
Lin.Wood@BryanCave.com
4
5. 4:08-cv-02753-TLW-TER Date Filed 10/27/09 Entry Number 77 Page 5 of 5
CERTIFICATE OF SERVICE
I hereby certify that on October 27, 2009, I electronically filed the foregoing document
with the Clerk of Court, which will automatically send notification of such filing to the following
attorneys of record:
R. Scott Joye Susan P. MacDonald
Joye, Nappier & Risher, LLC Nelson Mullins Riley & Scarborough LLP
3575 Highway 17 Business Beach First Center, 3rd Floor
Murrells Inlet, SC 29576 3751 Robert M. Grissom Parkway
Myrtle Beach, SC 29577
Susan M. Brown
The Law Offices of Susan M. Brown P.C.
525 Clubhouse Drive
Peachtree City, GA 30269
This 27th day of October, 2009.
/s/ Louis Nettles
Louis Nettles
(District Court ID No. 2521)
Louis@folkenslaw.com
6025913
5